Over 20 years ago, Congress enacted the Americans with Disabilities Act (ADA), which was signed into law on July 26, 1990. 42 U.S.C. §§ 12101-12213. The ADA made it a violation of federal law to discriminate against a person with a disability in private sector and state and local government employment, in the provision of state and local government services, and in the provision of goods and services by places of public accommodation. The ADA is a mandate for equality for persons with disabilities, many of whom throughout our country’s history have been constrained by societal, cultural, and structural barriers that limited opportunities for them to achieve their potential, live independently, obtain gainful employment, and participate meaningfully in our shared American life. The ADA’s implementation has rendered much of our society more open and inclusive; considerations of accessibility feature more prominently today than in the past in the implementation of state and local government programs, as well as the provision of private sector services and facilities. These changes have empowered people with disabilities to participate in American society to an extent never before possible.

In the federal sector,
government agencies have long been subject to the accessible design
requirements of the Architectural Barriers Act of 1968, 42 U.S.C. §§ 4151-4156,
and the employment nondiscrimination requirements of Section 501 of the
Rehabilitation Act of 1973, 29 U.S.C. § 791.
In 1978, Congress amended Section 504 of the Rehabilitation Act of 1973
(Section 504) to extend the disability nondiscrimination obligations imposed on
recipients of federal financial assistance to the programs and activities of
federal agencies. 29 U.S.C. § 794. And, in 1998, Congress
amended Section 508 of the Rehabilitation Act (Section 508) to require federal
agencies to ensure that the electronic and information technology (EIT) they
procure, develop, maintain, and use is accessible to people with disabilities. 29 U.S.C. § 794d.
Section 508 is designed to fulfill the promise inherent in information
technology to enhance the lives of persons with and without disabilities.

In April 2000 the
Department of Justice issued its first report pursuant to Section 508, which
described the state of accessibility of the federal government’s EIT for people
with disabilities. The 2000 report
included detailed findings of fact based on the results of a 1999
self-evaluation by federal agencies. The
report also included recommendations, for example, to increase coordination
among federal agencies, including establishing an interagency technical
assistance support center, to form intra-agency voluntary advisory committees
comprised of persons with disabilities to assist in the identification and
resolution of accessibility issues, to develop agency-wide guidelines for
web-page development, and to develop systemic procedures to ensure procurement
of accessible EIT products.

On the tenth anniversary of
the ADA, on July 26, 2000, then President Clinton called upon the heads of the
executive departments and agencies to renew their commitment to ensuring that
federal programs were free of disability-based discrimination, including all
programs offered on government Internet and Intranet sites, and he encouraged
coordination among government agencies to ensure the success of their efforts
to make EIT accessible to persons with disabilities pursuant to Section
508. The memorandum emphasized that an
“important goal of the [Rehabilitation] Act for the Federal Government is to
set an example for the rest of the country by . . . providing exemplary service
to its customers with disabilities.”
President‘s Memorandum for the Heads of Executive Departments and
Agencies on Renewing the Commitment to Ensure that Federal Programs are Free
from Disability-Based Discrimination, 36
Weekly Comp. Pres. Doc. 1688 (July 31, 2000).

EIT Accessibility Standards
implementing Section 508 were published by the U.S. Architectural and
Transportation Compliance Board (Access Board) in late 2000 and the Federal
Acquisition Regulation was amended to incorporate the Access Board’s Section
508 Standards in 2001. Section 508
became enforceable in June 2001.

In recognition of the important role that technology can play in advancing opportunities for workplace and community participation by persons with disabilities, then President Bush on February 1, 2001, embarked on a number of efforts designed to promote the development of assistive and universally designed technologies for individuals with disabilities. For example, under the Assistive Technology Act, matching grants to States were awarded to help people with disabilities purchase assistive technology. A new website, www.DisabilityInfo.gov (now www.Disability.gov), was launched by the government to provide information in an accessible format to persons with disabilities concerning programs and activities of interest across the government. And, to facilitate a common understanding among federal agencies of Section 508 requirements, an interagency Section 508 Steering Committee and Coordinators’ Working Group were formed to work closely with federal agencies responsible for Section 508 and coordinate technical guidance and training.

In 2001 and 2004 the
Department of Justice surveyed federal agencies regarding the status of their
efforts to comply with Section 508. In
mid-2004, the Department published on its website at www.usdoj.gov/crt/508/report2/index.php a report based on the results of the 2001 Survey [1]. The report included findings and offered
recommendations regarding web accessibility, the processing of Section 508
administrative complaints, agency policies and practices concerning
telecommunications devices and information transaction machines, and it offered
some guidance on the interplay of Sections 501 and 504 of the Rehabilitation
Act on the federal government’s obligations under Section 508.

On President Obama’s second day in office, on January 21, 2009, he issued a call for openness and transparency in the manner in which the federal government interacts with citizens and provides information about government programs and activities. President’s Memorandum for the Heads of Executive Agencies on Transparency and Open Government, 74 Fed. Reg. 4685 (January 26, 2009). More recently, on May 23, 2012, the President issued a directive entitled “Building a 21st Century Digital Government,” which launched a comprehensive Digital Government Strategy aimed at delivering better digital services to the American people. President’s Memorandum for the Heads of Executive Departments and Agencies on Building a 21st Century Digital Government, 77 Fed. Reg. 106 (June 1, 2012). These mandates can only be fully realized, however, when persons with disabilities have comparable access to government information and data. Federal agencies operate today in a more dynamic information environment than ever before and vigilance is required to make sure that the requirements of Section 508 continue to guide the procurement, development, maintenance, and use of EIT in all of its various forms. With recent advancements in technology, opportunities for communicating with the public have grown exponentially to include not only the Internet as traditionally used to provide information, but also new Internet-based social networking communities where people can respond to information provided to them, such as Facebook, Twitter, MySpace and YouTube. These expansions in technology hold the promise of increased participation for all, but present challenges for the full inclusion of persons with disabilities.

President Obama is committed to removing those barriers that remain in our society and that exclude people with disabilities, depriving them of true equality of opportunity and independence. In seeking to do more for Americans with disabilities, he is motivated by the principles of improving health care, increasing employment opportunities, expanding educational opportunities, protecting civil rights, promoting community living, supporting accessible technology, and supporting international disability rights. Compliance with Section 508 can facilitate achievement of the President’s objectives by removing many of the barriers to EIT that impede persons with disabilities’ access. For example, accessible EIT can open up to persons with disabilities information about government assistance for education and training programs, housing, and other government services and benefits, much of which is available on agency websites or is communicated to the public using agency telecommunication services, agency information kiosks, and transaction machines. Accessible EIT can also facilitate achievement of the federal government’s goal of increased federal hiring, promotion, retention, and success of people with disabilities, as illustrated by Executive Order Number 13548, Increasing Federal Employment of Individuals with Disabilities, 75 Fed. Reg. 45,039 (July 26, 2010). Executive Order 13548 calls for the heads of executive agencies to take steps to increase the employment of persons with disabilities. The executive order emphasized that agencies should implement strategies for hiring and retaining workers with disabilities, including by “increasing access to appropriate accessible technologies, and ensuring the accessibility of physical and virtual workspaces.”

This report examines the
state of federal agencies’ compliance with Section 508 during fiscal year 2010
(FY2010). The survey was
administered to federal agencies in early 2011.
It is hoped that the report’s findings can serve as a benchmark against
which progress towards an even more open, transparent, and inclusive EIT
environment within federal agencies can be assessed in the future.

Changes in technology continue at an extremely rapid pace, increasing the amount of EIT available to the American people, both with and without disabilities. Today, meaningful participation in American society requires access to a full range of EIT, including computers, office equipment, cellular telephones, software, and the Internet. Technological devices are increasingly portable, connected, and multifunctional, allowing a person to make a phone call, type a document, search the Internet, and send and receive e-mail from virtually anywhere in the country. The technological convergence of various modes of communication and information is continually evolving, changing the way the American people learn, work, consume goods and services, and communicate with each other.

People with disabilities have been among the
greatest beneficiaries of the technological advancement of EIT. However, people with disabilities also are at
significant risk of being excluded if the technological innovations are
designed without considering accessibility.
Section 508 of the Rehabilitation Act ensures that federal agencies
address these needs when they develop, procure, maintain, or use EIT. [2]

Section 508 of the Rehabilitation Act, as
amended by the Workforce Investment Act of 1998, requires federal agencies to
ensure that EIT is accessible to people with disabilities, unless certain
exceptions apply. Specifically, Section
508 requires federal agencies to ensure that EIT they develop, procure,
maintain, or use allows employees with disabilities and members of the public
seeking information or services to have access to and use of information and
data that is comparable to that available to employees and members of the
public without disabilities.

Because of the rapid changes in technology, in 2006, the Access Board began the process to update the Section 508 EIT Accessibility Standards by establishing an advisory committee. The advisory committee was composed of representatives from industry, disability groups, standard setting bodies in the United States and abroad, and government agencies. On April 3, 2008, the advisory committee presented its report and recommendations to the Access Board, and on March 22, 2010, the Access Board issued an advance notice of proposed rulemaking (ANPRM) to update and revise the Section 508 EIT Accessibility Standards. In response to comments, the Access Board made significant changes to the 2010 ANPRM and issued a second ANPRM on December 8, 2011. The comment period for the second ANPRM ended on March 7, 2012. The Access Board anticipates publishing a notice of proposed rulemaking in early 2013.

Section 508 requires the Attorney General to
submit to the President and Congress reports containing information on and
recommendations regarding the state of federal department and agency compliance
with Section 508, including actions regarding individual complaints. 29 U.S.C. § 794d(d)(2). Section 508 requires federal agencies to
cooperate with and to provide information to the Attorney General necessary to
assist with the reports. 29 U.S.C. § 794d(e).

Pursuant to this directive, in 2010-2011, the Department of Justice created survey instruments and solicited answers from federal agencies regarding their implementation of Section 508 in FY 2010.[3] The survey questions were based on prior survey efforts and finalized after consultation with participants from various federal agencies, including the Access Board, General Services Administration, Social Security Administration, and the Department of Homeland Security. The Department also consulted with many participants from federal government organizations including the Section 508 Coordinators, Federal Web Managers Council, and the Federal Chief Information Officers Council.

The survey requested data in four important areas: general processes for implementing Section 508, procurement, administrative complaints and civil actions, and website compliance. In order to obtain the most comprehensive and reliable data possible, the survey asked the federal agencies to identify components within each agency that were responsible for each category of duties referenced in each section of the survey. These agency components completed the survey and submitted the survey responses to their parent agency. The parent agency collected and provided the combined survey responses from all of their components to the Department. For purposes of the report, the survey responses were grouped according to their agency size category using the following breakdown:

Very Small 100 or fewer employees

Small 101 to 1,000 employees

Mid-Size 1,001 to 10,000 employees

Large 10,001 to 25,000 employees

Very Large 25,001 or more
employees

A total of 89 federal agencies, including Cabinet level agencies, independent agencies, and boards, commissions, and committees, participated in the Department of Justice's survey [4]. Twenty-six were very small agencies, 26 were small agencies, 18 were mid-size agencies, 6 were large agencies, and 13 were very large agencies. The 89 federal agencies identified a total of 318 components that provided the responses to the survey. This report provides the Department's findings and recommendations. The report also provides the data reported by the federal agency components and includes an analysis by agency size category.

Almost 15 years ago, Congress amended Section
508 of the Rehabilitation Act to require federal agencies to ensure that the
EIT they procure, develop, maintain, and use is accessible to people with
disabilities. Some agencies have
achieved substantial success in implementing and complying with Section
508. However, many agencies continue to
face significant challenges in adopting appropriate policies and procedures, establishing
a Section 508 office or program, providing training, coordinating efforts, and establishing
accountability.

The
first section of the Department’s survey focused on general processes for
implementing Section 508 within the agencies and their components. Specifically, this section sought information
regarding policies, processes, and procedures that agencies used to ensure
their components comply with the requirements of Section 508. In addition, agencies were asked questions
regarding their budgets for information technology (IT), development of
software and web applications, and training.
Also, agencies were asked several questions regarding Section 504
of the Rehabilitation Act (Section 504).

Agencies reported mixed levels of success. Slightly more than fifty percent of agency components had established a general policy to implement and comply with Section 508. However, only about forty percent of agency components that developed software had included a process to ensure the accessibility of software, and only about thirty percent of agency components that developed videos or multimedia productions had included a process to ensure the accessibility of training or informational videos or multimedia productions. Additionally, nearly seventy percent of agency components had appointed a Section 508 coordinator, but only thirty-five percent of agency components had established a Section 508 office or program. Among the agency components that had established a Section 508 office or program, they assigned on average 2.5 full time equivalents (FTEs) and allocated a median budget of $35,000 to their Section 508 office or program.[5]

Agency components experienced difficulty in
providing Section 508 training to their personnel - only forty percent of
agency components provided Section 508 training, and these agency components
provided only a small number of hours of training to their agency acquisition
workforce (less than one hour) or EIT developers (a little more than one hour). Agency components also experienced difficulty
establishing a mechanism to ensure EIT used
in a program or activity receiving federal financial assistance is accessible
to persons with disabilities .

The Department recommends the following:

Establish Section 508 Policies and Procedures. Agencies that have not already done so should establish policies and procedures to ensure that their development, procurement, maintenance, and use of EIT (web, software, office equipment, and other EIT) are accessible. The policies and procedures should identify the person in charge and define roles and responsibilities, especially for the agency’s personnel involved in the procurement process and web and software developers. The policies and procedures should include a process to regularly report on the status of Section 508 compliance and implementation to agency’s leadership. The policies and procedures should also include the technical requirements of Section 508 EIT Accessibility Standards, including the accessibility requirements for all live or recorded training and multimedia production (e.g., closed captioning, open captioning, and audio description).

Appoint Coordinators and Establish Section 508 Offices or Programs. Agencies that have not already done so should appoint a Section 508 coordinator and establish a Section 508 office or program. The Section 508 coordinator and the Section 508 office or program should reside in the office that plans and oversees the implementation of the agency’s information technology (e.g., Office of the Chief Information Officer or Chief Technology Officer). The Section 508 coordinator should have the authority to implement the agency’s Section 508 policy. The coordinator should also have the authority to facilitate and develop partnerships with agency components that are responsible for information technology, procurement, and enforcement of equal employment opportunity (EEO) or civil rights laws. The agency’s Section 508 office or program should support Section 508 compliance within the agency’s information technology governance activities to ensure that decisions regarding technology include the needs of employees and members of the public with disabilities. Additionally, the agency’s Section 508 office or program should provide support to agency personnel who are responsible for ensuring the accessibility of EIT that is developed, procured, maintained, or used. The Section 508 office or program should also provide support for accessibility testing and remediation of EIT.

Provide More Training to Agency Personnel. Agencies should provide and/or facilitate the provision of more training to Section 508 coordinators, agency personnel involved in the procurement process, software developers, website developers, and video and multimedia developers. Agencies should also provide training to equal employment opportunity, human resources, civil rights, and Section 508 offices and personnel. To provide more effective training, agencies should utilize the Section 508 expertise of the Access Board and the General Services Administration, which have statutory authority for providing technical assistance under Section 508. Agencies also should encourage the sharing of interagency training opportunities and take advantage of the existing Section 508 training opportunities, including the Section 508 Coordinators’ Conference and the Interagency Disability Educational Awareness Showcase.

Ensure Accessibility of EIT Used in Programs or Activities Receiving Federal Financial Assistance. Section 504 prohibits recipients from discriminating against persons with disabilities in any program or activity receiving federal financial assistance. Under this statute, recipients have an obligation to ensure that persons with disabilities are not excluded from, denied the benefits of, or subjected to discrimination under any program or activity receiving federal financial assistance, including instances when the program or activity is offered through the use of EIT (e.g., through websites).Agencies should inform recipients that they are required to ensure the accessibility of their websites and other EITs and that they may meet this statutory obligation by using the standards described under the Section 508 EIT Accessibility Standards.[6]

2. Procurement

The second section of the survey focused on
procurement practices and procedures within the federal agencies. Specifically, this section analyzed contract
requirements, market research, documentation of
decisions, exceptions and commercial non-availability, and pre or post award
protests.

A majority of the agency components currently
incorporate accessibility provisions into their EIT procurements. However, less than fifty percent of agency
components incorporated specific applicable Section 508 Accessibility Standards
as requirements in each procurement solicitations. A majority of the agency components only
provided standardized compliance language or clauses in their
solicitations. Additionally, instead of
relying on actual product testing to validate Section 508 compliance, agency
components most often relied on reviewing the materials submitted by the
contractor or vender to evaluate whether the deliverables met the Section 508
requirements. Some agency components
conducted no evaluation at all.

The Department recommends the following:

Develop Procurement Policies for Section 508 Compliance. As mentioned previously,
slightly more than fifty percent of agency components had established a
general policy to implement and comply with Section 508. Agencies that have not already done so
should review all of their procurement practices and policies, formal and
informal, and develop systematic ways to ensure that they are procuring
EIT that meets the Section 508 EIT Accessibility Standards.

Use Specific Language of the Section 508 Requirements in All
Solicitations.
Rather than rely on general Section 508 standardized language,
whenever possible, agencies should incorporate specific applicable Section
508 requirements that are appropriate for the procurement of the EIT
product.

Perform Actual Product Testing. Instead of solely relying on reviewing the materials submitted by the contractor or vendor, agencies should evaluate Section 508 compliance by conducting actual product testing throughout the acquisition process, particularly for products that will be heavily used by agency employees or members of the public. When product testing reveals noncompliance, an effective plan should be developed to correct or remediate the problem in a timely manner.

Establish Procedures to Document Section 508 Procurement Decisions. Only about forty percent
of agency components had established a formal policy to document any
Section 508 exceptions claimed on procurements of EIT. Agencies that have not already done so should
establish formalized systems to document their Section 508 procurement
decisions (e.g. , non-availability determination, undue burden exceptions, National Security exceptions).

The third section of the survey examined
policies and procedures for handling Section 508 complaints and requested
statistics on the number of complaints and judicial actions involving the
federal agencies. Agency components
reported 140 administrative complaints and seven civil actions since June 21,
2001, the effective date of the Section 508 EIT Accessibility Standards. However, most of the administrative
complaints and civil actions were filed against componets in very large agencies. Also, only slightly more
than thirty percent of agency components had already established set of
policies and procedures specifically to process Section 508
complaints. Fifty-seven percent of the
agency components were either using existing Section 504 complaint processes or
some other process.

The Department recommends the following:

Establish Procedures Specifically to Process Section 508 Complaints. Rather than rely solely on
the Section 504 complaint process, agencies should consider augmenting the
Section 504 complaint process, where appropriate, so as to include
specific policies and procedures targeted to the processing of Section 508
complaints. [7] The complaint policies and procedures
should also include a method for tracking the complaints and ensure a
timely response and resolution.

Incorporate Alternative Dispute Resolution Into Section 508
Complaint Process. Almost seventy percent of agency
components reported providing Section 508 complainants a choice of using
an Alternative Dispute Resolution (ADR) option to attempt resolution of their
complaints. Those agencies that
have not done so should consider offering to Section 508 complainants a
carefully designed ADR option within the context of the agencies’ Section
508 administrative complaint resolution process.

Disseminate Widely Information About the Section 508 Complaint
Process.
Agencies should widely distribute information about their Section
508 administrative complaint process.
For example, agencies should publish the complaint process on the
agencies’ Internet and Intranet websites, as well as publish information prominently
in equal employment opportunity handbooks and other appropriate publications.

The fourth section of the Department’s survey inquired about general policies and practices for developing accessible web pages within the federal agencies. Agencies also were asked to evaluate the accessibility of their external Internet home pages, internal Intranet home pages, web-based forms, and web-based applications. Seventy percent of agency components reported having accessibility policies in place for website development and that their web pages, web-based forms, and web-based applications were generally accessible. Also, nearly fifty-eight percent of agency components reported performing routine automated and/or manual evaluation and remediation on their websites. Specifically, twenty-eight percent of agency components performed both automated and manual evaluation, while twenty-four percent of agency components performed only manual evaluation, and six percent of agency components performed only automated evaluation. Agency components reported some difficulty, however, with providing captioning and audio description for multimedia content and providing keyboard accessibility.

The Department recommends the following:

Establish Web Accessibility Policies and
Procedures.
Agencies that have not already done so should establish web
accessibility policies and procedures to ensure that web developers follow
the requirements of the Section 508 EIT Accessibility Standards so as to
ensure that their web pages (both public and private) are accessible to
people with disabilities.

Ensure that Web Accessibility Policies and Procedures Include Special Topics. Agencies should ensure that their web accessibility policies and procedures include guidance to ensure that frequently used elements on their websites are accessible. Guidance should include, among other things, Adobe Acrobat files (.pdfs), video and audio multimedia content (closed captioning, open captioning, and audio description), JavaScript or other scripting languages, word processing files, data tables, skip navigation links, and online electronic forms.

Test Accessibility of Agency Web Pages. Agencies should include in their web accessibility policies and procedures a process to routinely and consistently test their web pages for accessibility. The most effective way to determine whether a web page is accessible to people with disabilities is to use both automated and manual testing. Manual testing should be based on a consistent test process and should rely primarily on code inspection to ensure that the web page is consistent with the Section 508 EIT Accessibility Standards. Also, agencies can improve accessibility and usabilty of a web page by including people with disabilities in the testing process using screen readers and other assistive technologies prior to posting. Agencies should establish policies and procedures that require both methods of testing web pages.

Publish E-Mail Addresses. Agencies should designate and advertise e-mail addresses on their websites to allow persons with disabilities to inform the agencies of accessibility problems encountered on their websites. Agencies can also use e-mail addresses to accept requests from persons with disabilities for information and documentation in alternate formats.

One significant challenge posed by Section 508 is the need for coordination between those with technological expertise and those with knowledge of disability access issues. Agencies should improve inter- and intra-agency coordination and collaboration among information technology personnel, procurement officials, EEO or civil rights professionals, end users with disabilities, and the private sector.

In 2010, the U.S. Chief Information Officers
Council (CIOC) formed an Accessibility Committee to serve as an interagency
forum to improve the federal government’s implementation of Section 508. Working in conjunction with the U.S. Access
Board, the Department of Justice, and the General Services Administration, the
Accessibility Committee hopes to provide a forum for federal agencies,
disability advocacy groups, industry, and academic stakeholders to enable and
support the federal government’s implementation of Section 508. The Accessibility Committee has begun to
develop and share best practices that address, among other things, Section 508
governance, procurement, testing, and training.

The formation of the CIOC Accessibility Committee is a positive step forward in promoting increased inter-agency coordination and awareness. At the same time, agencies will need to improve intra-agency coordination and collaboration among agency components that are responsible for information technology, procurement, and enforcement of EEO or civil rights laws. The participation of the agency’s EEO or civil rights office is especially important. For most agencies, Section 508 implementation has been the province of components that are responsible for the agency’s information technology or procurement. Today, some agencies view Section 508 as a set of technical requirements that they must comply with when developing, procuring, maintaining and using EIT. Section 508 is a federal civil rights law but agencies’ EEO or civil rights offices have been mostly absent from the implementation process.

The Department recommends the following to
increase coordination and cooperation:

Revive the Interagency Disability
Coordinating Council. The Department should revive the Interagency Disability
Coordinating Council (IDCC), as set forth in 29 U.S.C. §794c, with
the Attorney General as Chair, consistent with Executive Order 12250, 29
U.S.C. §2000d-1.

Issue Section 508 Model Complaint Resolution Policies and Procedures. The Department, in consultation with the IDCC after it is reconvened, should review agencies’ complaint resolution policies and procedures for Section 508 and recommend improvements and best practices.

Issue Guidance Clarifying the
Relationship Among Sections 501, 504, and 508 of the Rehabilitation Act.
The IDCC should issue guidance clarifying the relationship among Sections
501, 504, and 508 of the Rehabilitation Act.

This section of the survey focused on general processes for implementing Section 508 within the agencies and their components. Specifically, this section sought information regarding policies, processes, and procedures that agencies used to ensure compliance with the full requirements of Section 508, including EIT that is procured, developed, maintained or used by federal agencies. In addition, agencies were asked questions regarding their budget or spending on information technology (IT), development of software and web applications, and training. Also, agencies were asked several questions regarding Section 504 of the Rehabilitation Act (Section 504).

The general processes section focused on ten
specific areas:

Section 508 Policy

Section 508 Office or Program

Spending on IT and Section 508

Software and Other EIT

Section 508 Technical Requirements

Section 508 Functional Performance
Requirements

Section 508 Information and
Documentation Requirements

Section 508 Training

Section 508 Challenges

Other Rehabilitation Act Issues

The following provides a brief summary of
findings for each of the ten subsections of Section II – General Processes
for Section 508 Implementation.

Section 508 Policy. Slightly more than fifty percent of agency
components established a formal, written policy to implement and comply
with Section 508. The head of an
agency or the agency’s office of the chief information officer established
the majority of the agency components’ Section 508 policies. Most Section 508 policies identified the
office or person responsible, and defined some roles and responsibilities
for Section 508 coordinators, requiring officials, contracting officers,
application developers, and web content managers and authors.

Section 508 Office or Program. Nearly seventy percent of agency
components appointed a Section 508 coordinator. Also, nearly thirty-five percent of
agency components established a Section 508 office or program. On average, agency components assigned
2.5 full time equivalents (FTEs) and allocated a budget of $413,497 to
their Section 508 office or program. [8] However, it is important to note
that the average budget for larger agency components was significantly
higher than the average budget for smaller agency components, which has an
effect of skewing the figure. Across all agency size categories,
the median budget was $35,000 for their Section 508 office or program. In addition, the most common
service provided by agency components that had established a Section 508
office or program was to evaluate the accessibility of websites, and the
least common service provided was to evaluate the accessibility of
hardware.

Spending on IT and Section 508. Agency components reported an average IT
budget of $390,024,414. However, it is
important to note that the average IT budget for larger agency components
is significantly higher than the average IT budget for smaller agency
components, which has the effect of skewing the figure. Also, nearly seventy
percent of agency components reported allocating or using resources to
implement and comply with Section 508. However, eighty-five percent of agency
components did not track their spending to implement and comply with Section
508. Those agency components that
tracked their spending, reported an average budget or spending of
$5,785,963 to implement and comply with Section 508. [9] However, again, it is important to
note that the average budget for larger agency components was
significantly higher than the average budget for smaller agency components,
which has the effect of skewing the figure. Across all agency size categories,
the median spending was $140,000 to implement and comply with Section 508. The most common service
provided by agency components, regardless of whether they had established
a Section 508 office or program, was to evaluate the accessibility of
websites, and the least common service provided was to evaluate the
accessibility of hardware.

Software and Other EIT. Seventy-five percent of agency components reported developing software or web applications. About forty percent of these agency components reported establishing a policy to ensure the accessibility of software, including testing developed software for Section 508 compliance. Nearly seventy-one percent of agency components reported developing training or informational videos or multimedia productions. About thirty percent of these agency components reported establishing a policy to ensure the accessibility of videos or multimedia productions, including testing developed videos or multimedia production for Section 508 compliance.

Section 508 Technical Requirements. The percentage of agency
components or parts of their components establishing policies to comply
with each of the six subparts of the technical requirements of the Section
508 EIT Accessibility Standards varied from forty-three percent for
self-contained, closed products to sixty percent for websites.

Section 508 Functional Performance Requirements. Nearly fifty percent of agency
components or parts of their components established formal, written
policies to comply with the functional performance requirements in Section
508 EIT Accessibility Standards. Thirty-three
percent of agency components reported not establishing a policy and had no
plans to establish a policy to comply with the functional performance
requirements.

Section 508 Information and Documentation Requirements. Website, E-mail, and large
print were the most common alternate formats used by agency components to
provide individuals with disabilities access to information and
documentation for EIT products.
Braille was the least common alternate formats used by agency
components. Similarly, website,
E-mail, TTY, and sign language were the most common alternate methods used
by agency components. Mobile
texting was the least common alternate method used by agency components.

Section 508 Training. Nearly sixty percent of agency
components reported not providing Section 508 training to their
employees. Slightly more than forty
percent of agency components reported providing Section 508 training. Agency components reported providing the
most average hours of training to Section 508 coordinators (a little more
than four hours) and the fewest average hours of training to IT help desk
staff (less than one hour). Very
small agency components reported the highest number of average hours of
Section 508 training for many of the available types of employees. A majority of agency
components that offered training reported online training as the most
common method for providing Section 508 training. By contrast, mid-size agency components reported classroom instruction and
conferences as their most common method for providing Section 508
training.

Section 508 Challenges. Many agency components reported lack of
resources, lack of general awareness, and lack of training as the three
most common challenges in implementing and complying with Section
508. By contrast, lack of
management support was the least common challenge. Interestingly, fifteen percent of agency
components could not identify any challenges in implementing and complying
with Section 508.

Other Rehabilitation Act Issues. Nearly forty percent of agency
components that provided federal financial assistance reported not having
any knowledge whether recipients of federal financial assistance were
required to ensure accessibility of websites and other EITs. Another twenty-four percent of agency
components did not require recipients to ensure accessibility of websites
and other EITs. Thirty-five percent
of agency components or parts of their components reported requiring
recipients of federal financial assistance to ensure accessibility of websites
and other EITs. Among these agency
components, a majority reported establishing an EIT
accessibility policy or parts of their components establishing an EIT
accessibility policy for recipients of federal financial assistance.

Agencies and their components were asked questions
relating to their policies and procedures to implement Section 508. A total of 318 agency components participated
in this section.

The following provides a summary
description of the agency components’ responses:

Slightly more than fifty percent of agency components reported they
established a formal, written policy to implement and comply with Section
508.

The majority of the Section 508 policies were established by the
head of the agency or the agency’s office of the chief information
officer.

Most agency components reported that their Section 508 policy
identified the office or person responsible for implementing and complying
with Section 508.

A majority of the agency components reported that their Section 508
policy defined some roles and responsibilities for Section 508
coordinators, requiring officials, contracting officers, application
developers, and web content managers and authors.

Question
1 asked whether agency components established
a formal, written policy to implement and comply with Section 508. Those agency components that did not
establish a formal, written policy were asked to skip the remaining questions in
this section and proceed to the next section regarding the Section 508 Office
or Program. In general, a majority of agency
components (51.3%) established a Section 508 policy. More components of larger agencies established
a Section 508 policy compared to components of smaller agencies. Seventy-seven agency components (24.2%) reported
not establishing a Section 508 policy but established a schedule to develop a
policy. Surprisingly, 76 agency
components (23.9%) reported not establishing a Section 508 policy and had no
plan to develop a policy.

The following table provides the
specific responses by the agency components:

Section 508 Policy by Number (Percent) of Components in Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established

163 (51.3%)

103 (57.9%)

36 (52.9%)

7 (38.9%)

8 (28.6%)

9 (34.6%)

(b) No, but a timetable was established to do so

77 (24.2%)

34 (19.1%)

9 (13.2%)

9 (50.0%)

13 (46.4%)

12 (46.2%)

(c) No, and there were no plans to do so

76 (23.9%)

41 (23.0%)

23 (33.8%)

2 (11.1%)

7 (25.0%)

3 (11.5%)

(d) Don’t know

2 (0.6%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

2 (7.7%)

Question
2 asked agency components to identify the highest office within the
agency that established the Section 508 policy.
A total of 163 agency components that established a Section 508 policy
responded to this survey question. Overall,
a majority of the agency components reported that either the head of the agency
or the agency’s office of the chief information officer established the Section
508 policy. Specifically, 65 agency
components (39.9%) reported that the agency’s office of the chief information
officer established the Section 508 policy.
Forty-eight agency components (29.4%) reported that the head of the
agency established the Section 508 policy.
Twenty-seven agency components (16.6%) reported that the agency’s
Section 508 office or coordinator established the Section 508 policy. Only 1 agency component (0.6%) reported that
the agency’s civil rights office established the Section 508 policy.

The agency components’ responses are summarized
in the table below:

Section 508 Policy by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Head of the agency

48 (29.4%)

29 (28.2%)

10 (27.8%)

2 (28.6%)

1 (12.5%)

6 (66.7%)

(b) CIO office

65 (39.9%)

47 (45.6%)

7 (19.4%)

3 (42.9%)

6 (75.0%)

2 (22.2%)

(c) Civil rights
office

1 (0.6%)

1 (1.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(d) Section 508 office or coordinator

27 (16.6%)

16 (15.5%)

9 (25.0%)

1 (14.3%)

0 (0.0%)

1 (11.1%)

(e) Other

22 (13.5%)

10 (9.7%)

10 (27.8%)

1 (14.3%)

1 (12.5%)

0 (0.0%)

Question
3 asked agency components whether their Section 508 policy identified the
office or person responsible for implementing and complying with Section
508. Overall, most of the agency
components (85.9%) reported that their Section 508 policy identified the office
or person responsible for implementing and complying with Section 508. Eleven agency components (6.7%) reported that
their Section 508 policy did not identify the office or person responsible for
implementing Section 508 but established a schedule to identify the office or
person. Twelve agency components (7.4%)
reported that their Section 508 policy did not identify the office or person
responsible for implementing Section 508 and had no plan to identify the office
or person.

The following table provides the agency components’
responses:

Section 508 Policy – Office or Person
in Charge by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, the policy identifies the office or person who is
responsible

140 (85.9%)

88 (85.4%)

30 (83.3%)

7 (100.0%)

7 (87.5%)

8 (88.9%)

(b) No, but a
timetable was established to do so

11 (6.7%)

4 (3.9%)

5 (13.9%)

0 (0.0%)

1 (12.5%)

1 (11.1%)

(c) No, and
there were no plans to do so

12 (7.4%)

11 (10.7%)

1 (2.8%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

Question
4 asked agency components whether their Section 508 policy defined roles
and responsibilities for Section 508 coordinators, requiring officials,
contracting officers, application developers, and web content managers and authors. Overall, a majority of agency components (58.3%)
reported that their Section 508 policy defined some roles and
responsibilities. Another 50 agency
components (30.7%) reported that their Section 508 policy defined all roles and
responsibilities. Ten agency components (6.1%)
reported that their Section 508 policy did not define any roles and responsibilities
and had no plan to define roles and responsibilities.

The agency components reported the following:

Section 508 Policy on Roles and
Responsibilities by Number (Percent) of Components in Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, roles and responsibilities were defined

50 (30.7%)

31 (30.1%)

13 (36.1%)

3 (42.9%)

1 (12.5%)

2 (22.2%)

(b) Yes and no,
some roles and responsibilities were defined, while others were not

Agencies and their components were asked questions
relating to their Section 508 office or program. A total of 318 agency components participated
in this section. However, 81 agency
components did not complete this section because they have not established a
Section 508 office or program.

The following provides a summary description
of the agency components’ responses:

Nearly seventy percent of agency components had appointed a Section
508 coordinator.

Nearly thirty-five percent of agency components had established a
Section 508 office or program. Another twenty-five percent of components
did not establish an office or program, but utilized their parent agency’s
Section 508 office or program.

Agency components that established a Section 508 office or program reported
assigning 2.5 average number of FTEs and
allocated an average budget of $413,497 for their Section 508
office or program. [10] However, it is important to note that the
average budget for larger agency components was significantly higher than
the average budget for smaller agency components, which has the effect of
skewing the figure. Across all agency size categories,
the median budget was $35,000 for their Section 508 office or program.

Agency components reported that the most common service provided by
their Section 508 office or program was to evaluate the accessibility of
websites. By contrast, the least
common service provided by agency components’ Section 508 office or
program was to evaluate the accessibility of hardware.

Question
1 asked whether agency components selected a Section 508
coordinator. A majority of the agency
components (69.8%) reported that they selected a Section 508 coordinator. Thirty-four agency components (10.7%)
reported not having a Section 508 coordinator but established a schedule to
select a coordinator. Interestingly, 61
agency components (19.2%) reported not having a Section 508 coordinator and had
no plan to select a coordinator.

The following table provides the specific
responses by the agency components:

Section 508 Coordinator by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a coordinator was selected

222 (69.8%)

127 (71.3%)

45 (66.2%)

15 (83.3%)

18 (64.3%)

17 (65.4%)

(b) No, but a
timetable was established to do so

34 (10.7%)

19 (10.7%)

4 (5.9%)

2 (11.1%)

6 (21.4%)

3 (11.5%)

(c) No, and
there were no plans to do so

61 (19.2%)

32 (18.0%)

19 (27.9%)

1 (5.6%)

4 (14.3%)

5 (19.2%)

(d) Don't know

1 (0.3%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

1 (3.8%)

Question
2 asked whether agency components established an office or program to ensure
their compliance with Section 508. Those
agency components that did not establish a Section 508 office or program were
asked to skip the remaining questions in this section and proceed to the next
section regarding the Spending on Information Technology and Section 508. A majority of the agency components (60.1%) either
established a Section 508 office or program, or relied on their parent agency’s
Section 508 office or program. Surprisingly,
78 agency components (24.5%) reported not establishing a Section 508 office or
program and had no plan to establish an office or program. A significantly higher number of very large
agency components reported establishing a Section 508 office or program.

The agency components’ responses are
summarized in the table below:

Section 508 Office or Program by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, an office or a program was established

110 (34.6%)

74 (41.6%)

15 (22.1%)

5 (27.8%)

6 (21.4%)

10 (38.5%)

(b) No, but we utilize our agency’s Section 508 office or program

81 (25.5%)

48 (26.9%)

33 (48.5%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(c) No, but a
timetable was established to do so

46 (14.5%)

16 (9.0%)

4 (5.9%)

6 (33.3%)

13 (46.4%)

7 (26.9%)

(d) No, and
there were no plans to do so

78 (24.5%)

40 (22.5%)

16 (23.5%)

7 (38.9%)

8 (28.6%)

7 (26.9%)

(e) Don't know

3 (0.9%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

1 (3.6%)

2 (7.7%)

Question
3 asked agency components the number of FTEs assigned to their Section
508 office or program. A total of 110
agency components that established a Section 508 office or program responded to
this survey question. Across all agency
size categories, agency components reported assigning 2.5 average number of FTEs to a Section 508 office or program. [11] Interestingly, the mid-size agency components
reported the largest number of average FTEs, 5.4. The small and very small agency components
reported the smallest number of average FTEs, 0.4 and 1.1, respectively.

The following table provides the agency components’
responses:

Section 508 Office or Program FTEs by
Number of FTEs Among Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

Question 3: How many FTEs does your agency component have in its Section 508
office or program?

2.5

2.5

3.3

5.4

0.4

1.1

Question
4 asked agency components that established a Section 508 office or
program to estimate their budget. Overall,
agency components reported an average budget of $413,497 for their Section 508 office or program. [12]
However, it is important to note that the average budget for larger
agency components is significantly higher than the average budget for smaller
agency components, which has the effect of skewing the figure. Across all agency size categories, the median budget was $35,000
for their Section 508 office or program.

The following table provides the agency components’
responses:

Section 508 Office or Program Budget by
Average Number of Dollars Among Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

Question 4: What was your agency component's budget for its Section 508
office or program?

$413,497

$557,584

$208,305

$76,000

$13,698

$0

Question
5 asked agency components that had established a Section 508 office or
program to identify the types of services offered to implement and comply with
Section 508. A total of 110 agency
components responded to this survey question.
In this question, agency components were allowed to select any
number of available options. Thus, the
total of percentages within each column of the table may exceed 100%.

Overall, the most common services provided by
an agency component’s Section 508 office or program were to evaluate website
accessibility (74.5%), provide training (69.1%), and assist acquisition
officials prepare Section 508 language in EIT contracts (65.5%). By contrast, the least common service
provided by an agency component was to evaluate hardware accessibility (40.0%). Interestingly, a higher percentage of large
(73.3%) and small (83.3%) agency components assisted developers to design
software that complies with Section 508 than very large, mid-size, or very
small agency components. Also, a higher
percentage of small (83.3%) and very small (70.0%) agency components created or
repaired electronic documents to comply with Section 508 than very large,
large, or mid-size agency components.

The agency components reported the following:

Section 508 Services Provided by Number
(Percent) of Components in Differently-Sized Agencies

Agencies and their components were asked questions
relating to their investments in IT and Section 508. A total of 318 agency components participated
in this section. However, 35 agency
components did not complete this section because the information was
classified.

The following is a summary of agency
components’ responses:

Agency components reported an average IT budget or spending of $390,024,414. However, it is important to note that
the average IT budget for larger agency components is significantly higher
than the average IT budget for smaller agency components, which has the
effect of skewing the figure. The
amount of the IT budget or spending was generally relative to the agency
size categories: the larger the
agency, the larger the IT budget or spending. There was one exception to this trend,
mid-size agencies reported an average IT budget or spending of
$129,835,018, which was more than double the average IT budget or spending
of large agencies.

Nearly seventy percent of agency components reported allocating or
using resources to implement and comply with Section 508.

Eighty-five percent of agency components reported not tracking
their spending to implement and comply with Section 508. About fifteen percent of agency
components reported tracking their spending.

Agency components that tracked their spending reported an average budget
or spending of $5,785,963 to implement and comply with Section 508. [13] However, it is important to note that the
average budget for larger agency components was significantly higher than
the average budget for smaller agency components, which has the effect of
skewing the figure. Across all agency size categories,
the median budget or spending was $140,000 to implement and comply with
Section 508.

Agency components, regardless of whether they established a Section
508 office or program, reported that the most common service provided was
to evaluate websites for Section 508 compliance. By contrast, the least common service provided
was to evaluate hardware.

Question
1 asked agency components to estimate their total budget or spending for
information technology (IT). Those
agency components that could not provide their IT budget or spending were asked
to skip the remaining questions in this section and proceed to the next section
regarding Software and Other EIT.
Overall, agency components reported an average IT budget or spending of $390,024,414. However, it is important to note that the
average IT budget for larger agency components is significantly higher than the
average IT budget for smaller agency components, which has the effect of
skewing the figure. Generally, the amount
of the IT budget or spending was relative to the agency size category: larger the agency, larger the IT budget or
spending. There was one exception to
this trend, mid-size agencies reported an average IT budget or spending of $129,835,018,
which was more than double the average IT budget or spending of large agencies.

The following table provides the specific responses
by the agency components:

IT Budget or Spending by Average Number
of Dollars Among Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

Question 1: What was your agency component's IT budget or spending?

$390,024,414

$694,837,407

$58,446,353

$129,835,018

$9,438,433

$274,800

Question
2 asked whether agency components track their spending to implement and
comply with Section 508.
A total of 283 agency components that estimated their IT budget or
spending responded to this survey question.
Overall, a majority of agency components (85.2%) reported not tracking
their spending to implement and comply with Section 508. Only 42 agency components (14.8%) reported
tracking their spending.

The agency components’ responses are
summarized in the table below:

Section 508 Spending Tracking System by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a tracking system is in place

42 (14.8%)

23 (15.3%)

8 (12.7%)

1 (5.9%)

5 (18.5%)

5 (19.2%)

(b) No, but a
timetable was established to do so

46 (16.3%)

18 (12.0%)

12 (19.0%)

4 (23.5%)

5 (18.5%)

7 (26.9%)

(c) No, and
there were no plans to do so

158 (55.8%)

86 (57.3%)

34 (54.0%)

11 (64.7%)

14 (51.9%)

13 (50.0%)

(d) Don't know

37 (13.1%)

23 (15.3%)

9 (14.3%)

1 (5.9%)

3 (11.1%)

1 (3.8%)

Question
3 asked agency components to estimate their budget or spending to
implement and comply with Section 508. A total of 42 agency components that tracked
their budget or spending responded to this survey question. Overall, agency components reported an
average budget or spending of $5,785,963 to implement and comply with Section
508. [14] However,
it is important to note that the average budget for larger agency components
was significantly higher than the average budget for smaller agency components,
which has the effect of skewing the figure. Across all agency size categories, the median budget or
spending was $140,000 to implement and comply with Section 508.

The following table provides the agency components’
responses:

Section 508 Spending by Average Number
of Dollars Among Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

Question 3: What was your agency component's budget or spending to comply
with Section 508?

$5,785,963

$5,066,678

$15,708,157

$300,000

$36,314

$66,000

Question
4 asked whether agency components allocated or used resources to
implement and comply with Section 508. A total of 283 agency components responded to
this survey question. Overall, most agency
components (67.8%) reported allocating or using resources to implement and
comply with Section 508. Surprisingly, 18.8%
of agency components reported not allocating or using resources, and 13.4% of agency
components reported not knowing whether they allocated or used resources to
comply with Section 508.

The agency components reported the following:

Section 508 Spending by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, resources were used to comply with Section 508

192 (67.8%)

98 (65.3%)

44 (69.8%)

15 (88.2%)

20 (74.1%)

15 (57.7%)

(b) No, but a
timetable was established to do so

18 (6.4%)

9 (6.0%)

2 (3.2%)

0 (0.0%)

3 (11.1%)

4 (15.4%)

(c) No, and
there were no plans to do so

35 (12.4%)

16 (10.7%)

10 (15.9%)

2 (11.8%)

2 (7.4%)

5 (19.2%)

(d) Don't know

38 (13.4%)

27 (18.0%)

7 (11.1%)

0 (0.0%)

2 (7.4%)

2 (7.7%)

Question
5 asked whether agency components’ budget or spending to implement and
comply with Section 508 include spending to comply with Section 504. A total of 192 agency components that
allocated or used resources to comply with Section 508 responded to this survey
question. Across all agency size
categories, 77 agency components (40.1%) reported that resources for Section
508 compliance did not include resources to comply with Section 504. Sixty-five agency components (33.9%) reported
that resources to comply with Section 508 included resources to comply
with Section 504. Fifty agency
components (26.0%) selected the option “Don’t know.”

The following table summarizes the responses
provided by the agency components:

Section 508 Spending by Number
(Percent) of Components in Differently-Sized Agencies

Question
6 asked agency components, regardless of whether they had established a
Section 508 office or program, to identify the types of services offered to
implement and comply with Section 508. A
total of 192 agency components that allocated or used resources to comply with
Section 508 responded to this survey question.
This question permitted agency components to select any number of
available options. Thus, the total of
percentages within each column of the table may exceed 100%.

Across all agency size categories, the most
common services provided by agency components were to evaluate websites (81.3%),
create or repair electronic documents (70.3%), assist developers to design
software (66.1%), evaluate software (64.6%), and assist acquisition officials
prepare Section 508 language in EIT contracts (64.6%). By contrast, the least common service provided
by an agency component was to evaluate hardware (40.6%). Interestingly, a higher percentage of mid-size
agency components provided more of the following services than agency
components in all other size categories:
assist acquisition officials prepare EIT contracts, assist developers
design accessible software, remediate electronic documents, and evaluate
websites.

The following table provides the specific
responses by the agency components:

Section 508 Services Provided by Number
(Percent) of Components in Differently-Sized Agencies

Agencies and their components were asked questions
relating to their development of software and web applications. A total of 318 agency components participated
in this section. However, 79 agency
components did not complete this section because they did not develop software
or web applications.

The following provides a brief summary of the
agency components’ responses:

Seventy-five percent of agency components reported developing
software or web applications either in-house or by contractors. But only about forty percent of these agency
components reported establishing a policy to ensure the accessibility of
software, including testing developed software for Section 508 compliance.

Nearly seventy-one percent of agency components reported developing
training or informational videos or multimedia productions either in-house
or by contractors. But only about
thirty percent of these agency components reported establishing a policy
to ensure the accessibility of videos or multimedia productions, including
testing developed videos or multimedia production for Section 508
compliance.

Question
1 asked whether agency components developed their own software or web
applications other than informational web pages. Those agency components that did not develop
software or web applications were asked to skip the remaining questions in this
section and proceed to the next section regarding the Section 508
Standards. For all but very small agency
components, the majority of agency components in all size categories reported
developing software or web applications either in-house (51.9%) or by
contractors (23.3%). Most of the very
small agency components (80.8%) reported that they do not develop software or
web applications.

The agency components’ responses are
summarized in the table below:

Software or Application Development by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, software was developed in-house

165 (51.9%)

96 (53.9%)

38 (55.9%)

11 (61.1%)

18 (64.3%)

2 (7.7%)

(b) Yes, but
development was limited to contractors

74 (23.3%)

44 (24.7%)

16 (23.5%)

6 (33.3%)

5 (17.9%)

3 (11.5%)

(c) No

79 (24.8%)

38 (21.3%)

14 (20.6%)

1 (5.6%)

5 (17.9%)

21 (80.8%)

Question
2 asked whether agency components established a formal, written policy to
ensure that software or web application complies with Section 508. A total of 239 agency components that
developed software responded to this survey question. Overall, 92 agency components (38.5%) reported
establishing a policy to ensure accessibility of software. Another 62 agency components (25.9%) reported
that only parts of their components had established a software policy. Surprisingly, 55 agency components (23.0%) reported
not establishing a policy and had no plan to establish a policy to ensure
accessibility of software.

The following table provides the agency components’
responses:

Software or Application Development
Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to ensure that
software development complies with Section 508

92 (38.5%)

62 (44.3%)

14 (10.0%)

8 (47.1%)

6 (26.1%)

2 (40.0%)

(b) Yes and no,
parts of our components have done this, while others have not

62 (25.9%)

34 (24.3%)

20 (37.0%)

3 (17.6%)

5 (21.7%)

0 (0.0%)

(c) No, but a
timetable was established to do so

30 (12.6%)

15 (10.7%)

2 (3.7%)

3 (17.6%)

7 (30.4%)

3 (60.0%)

(d) No, and
there were no plans to do so

55 (23.0%)

29 (20.7%)

18 (33.3%)

3 (17.6%)

5 (21.7%)

0 (0.0%)

Question
3 asked whether an agency component’s policy to ensure accessibility of
software included a process to review or evaluate developed software or web
applications for Section 508 compliance.
A total of 154 agency components that established a software policy responded
to this survey question. In general, 77 agency
components (50.0%) reported that their software policy included testing for
Section 508 compliance. Another 58
agency components (37.7%) reported that only parts of their components included
testing. Thirteen agency components
(8.4%) reported that their software policy does not include testing and had no
plan to include testing for Section 508 compliance.

The agency components reported the following:

Software or Application Testing Policy
by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to evaluate
developed software

77 (50.0%)

52 (54.2%)

14 (41.2%)

5 (45.5%)

4 (36.4%)

2 (100.0%)

(b) Yes and no,
parts of our components have done this, while others have not

58 (37.7%)

30 (31.3%)

17 (50.0%)

6 (54.5%)

5 (45.5%)

0 (0.0%)

(c) No, but a
timetable was established to do so

6 (3.9%)

3 (3.1%)

2 (5.9%)

0 (0.0%)

1 (9.1%)

0 (0.0%)

(d) No, and
there were no plans to do so

13 (8.4%)

11 (11.5%)

1 (2.9%)

0 (0.0%)

1 (9.1%)

0 (0.0%)

Question
4 asked whether agency components developed training or informational
videos or multimedia productions. Those
agency components that did not develop videos or multimedia productions were
asked to skip the remaining questions in this section and proceed to the next
section regarding the Section 508 Standards.
A total of 239 agency components responded to this survey question. Overall, a majority of agency components reported
developing videos or multimedia productions either in-house (52.3%) or by
contractors (18.4%). Seventy agency components
(29.3%) reported that they did not develop videos or multimedia productions or
all productions were purchased.

The following table summarizes the responses
provided by the agency components:

Video or Multimedia Production by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, video or
multimedia production was developed in-house

125 (52.3%)

76 (54.3%)

23 (42.6%)

10 (58.8%)

15 (65.2%)

1 (20.0%)

(b) Yes,
but the production was limited to contractors

44 (18.4%)

23 (16.4%)

12 (22.2%)

5 (29.4%)

2 (8.7%)

2 (40.0%)

(c) No, all
productions were procured or we do not create any video or multimedia
productions

70 (29.3%)

41 (29.3%)

19 (35.2%)

2 (11.8%)

6 (26.1%)

2 (40.0%)

Question
5 asked whether agency components established a formal, written policy to
ensure that training or informational videos or multimedia productions comply
with Section 508. Those agency
components that did not establish a policy to develop accessible videos or
multimedia productions were asked to skip the remaining questions in this
section and proceed to the next section regarding the Section 508
Standards. A total of 169 agency
components that developed videos or multimedia productions responded to this
survey question. For all but small
agency components, a majority of agency components in all size categories
reported establishing a policy (31.4%) or parts of their components
establishing a policy (33.1%) to ensure that videos or multimedia productions
comply with Section 508. The majority of
small agency components (64.7%) reported they did not establish a policy to
ensure accessible training or informational videos or multimedia productions.

The following table provides the specific
responses by the agency components:

Video or Multimedia Production Policy
by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to ensure that
video or multimedia production complies with Section 508

53 (31.4%)

35 (35.4%)

9 (25.7%)

3 (20.0%)

3 (17.6%)

3 (100.0%)

(b) Yes and no,
parts of our components have done this, while others have not

56 (33.1%)

30 (30.3%)

16 (45.7%)

7 (46.7%)

3 (17.6%)

0 (0.0%)

(c) No, but a
timetable was established to do so

27 (16.0%)

14 (14.1%)

3 (8.6%)

2 (13.3%)

8 (47.1%)

0 (0.0%)

(d) No, and
there were no plans to do so

33 (19.5%)

20 (20.2%)

7 (20.0%)

3 (20.0%)

3 (17.6%)

0 (0.0%)

Question
6 asked whether an agency component’s policy to ensure accessibility of
training or informational videos or multimedia productions included a process
to review or evaluate developed videos or multimedia productions for Section
508 compliance. A total of 109 agency
components that established a policy to ensure accessibility of videos or
multimedia productions responded to this survey question. Overall, 49 agency components (45.0%)
reported that their video or multimedia production policy included testing for
Section 508 compliance. Another 47
agency components (43.1%) reported that only parts of their components included
testing. Nine agency components (8.3%)
reported that their video or multimedia production policy does not include
testing and had no plan to include testing for Section 508 compliance.

The following table provides the specific
responses by the agency components:

Video or Multimedia Production Testing
Policy by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to evaluate video
or multimedia productions

49 (45.0%)

34 (52.3%)

9 (36.0%)

1 (10.0%)

2 (33.3%)

3 (100.0%)

(b) Yes and no,
parts of our components have done this, while others have not

The Section 508 EIT Accessibility Standards
contain technical requirements for six specific technology areas: software applications and operating systems,
web-based information or applications, telecommunication products, video and
multimedia products, self contained, closed products (e.g. , information kiosks,
calculators, and fax machines), and desktop and portable computers. In this section, agencies and their
components were asked questions relating to their policies and procedures to
comply with the technical requirements of the Section 508 EIT Accessibility
Standards. A total of 318 agency
components participated in this section.

The following provides a summary description
of the agency components’ responses:

Software. Nearly fifty-four percent of agency
components reported establishing a policy or parts of their components
establishing a policy to comply with the technical requirements for
software. Twenty-four percent of
agency components reported not establishing a policy and had no plans to establish
a policy to comply with the technical requirements for software.

Websites. Nearly sixty percent of agency
components reported establishing a policy or parts of their components
establishing a policy to comply with the technical requirements for
websites. Twenty-three percent of
agency components reported not establishing a policy and had no plans to
establish a policy to comply with the technical requirements for websites.

Telecommunication Products. Forty-eight percent of agency components
reported establishing a policy or parts of their components establishing a
policy to comply with the technical requirements for telecommunication
products. Nearly twenty-four
percent of agency components reported not establishing a policy and had no
plans to establish a policy to comply with the technical requirements for
telecommunication products.

Video and Multimedia Products. Nearly forty-six percent of agency
components reported establishing a policy or parts of their components
establishing a policy to comply with the technical requirements for video
and multimedia products. Twenty-four
percent of agency components reported not establishing a policy and had no
plans to establish a policy to comply with the technical requirements for
video and multimedia products.

Self Contained, Closed Products. Forty-three percent of agency components
reported establishing a policy or parts of their components establishing a
policy to comply with the technical requirements for self contained,
closed products. Twenty-one percent
of agency components reported not establishing a policy and had no plans
to establish a policy to comply with the technical requirements for self
contained, closed products.

Desktop and Portable Computers. Fifty percent of agency components
reported establishing a policy or parts of their components establishing a
policy to comply with the technical requirements for desktop and portable
computers. Twenty-seven percent of
agency components reported not establishing a policy and had no plans to
establish a policy to comply with the technical requirements for desktop
and portable computers.

Question
1(a) asked whether agency components established
policies and procedures to comply with the technical requirements for software applications
and operating systems in the Section 508 EIT Accessibility Standards. Overall, agency components reported establishing
a policy (32.1%) or parts of their components establishing a policy (21.4%) to
comply with the technical requirements for software. Another 78 agency components (24.5%) reported
not establishing a policy and had no plans to establish a policy to comply with
the technical requirements for software.
A higher percentage of very small agency components (30.8%) did not
establish a policy because they did not buy or develop software. The following tables provide the agency components’
responses:

Section 508 Standards on Software by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
software standards

102 (32.1%)

66 (37.1%)

19 (27.9%)

7 (38.9%)

6 (21.4%)

4 (15.4%)

(b) Yes and no,
parts of our components have done this, while others have not

68 (21.4%)

40 (22.5%)

18 (26.5%)

5 (27.8%)

4 (14.3%)

1 (3.8%)

(c) No, but a
timetable was established to do so

45 (14.2%)

19 (10.7%)

6 (8.8%)

3 (16.7%)

8 (28.6%)

9 (34.6%)

(d) No, and
there were no plans to do so

78 (24.5%)

39 (21.9%)

23 (33.8%)

3 (16.7%)

9 (32.1%)

4 (15.4%)

(e) No, we don't
buy or develop software

25 (7.9%)

14 (7.9%)

2 (2.9%)

0 (0.0%)

1 (3.6%)

8 (30.8%)

Question
1(b) asked whether agency components established
policies and procedures to comply with the technical requirements for web-based
information or applications in the Section 508 EIT Accessibility
Standards. Overall, agency components
reported establishing a policy (36.5%) or parts of their components
establishing a policy (23.0%) to comply with the technical requirements for
websites. Another 77 agency components
(24.2%) reported not establishing a policy and had no plans to establish a
policy to comply with the technical requirements for websites. A higher percentage of very small agency
components (23.1%) did not establish a policy because they did not buy, create,
or maintain websites.

The agency
components reported the following:

Section 508 Standards on Websites by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
web standards

116 (36.5%)

74 (41.6%)

23 (33.8%)

8 (44.4%)

4 (14.3%)

7 (26.9%)

(b) Yes and no,
parts of our components have done this, while others have not

73 (23.0%)

42 (23.6%)

16 (23.5%)

6 (33.3%)

8 (28.6%)

1 (3.8%)

(c) No, but a
timetable was established to do so

37 (11.6%)

17 (9.6%)

4 (5.9%)

2 (11.1%)

6 (21.4%)

8 (30.8%)

(d) No, and
there were no plans to do so

77 (24.2%)

39 (21.9%)

23 (33.8%)

2 (11.1%)

9 (32.1%)

4 (15.4%)

(e) No, we don't
buy, create or maintain websites

15 (4.7%)

6 (3.4%)

2 (2.9%)

0 (0.0%)

1 (3.6%)

6 (23.1%)

Question
1(c) asked whether agency components established
policies and procedures to comply with the technical requirements for
telecommunication products in the Section 508 EIT Accessibility Standards. Overall, agency components reported
establishing a policy (28.3%) or parts of their components establishing a
policy (19.8%) to comply with the technical requirements for telecommunication
products. Another 76 agency components
(23.9%) reported not establishing a policy and had no plans to establish a
policy to comply with the technical requirements for telecommunication
products. A higher percentage of very
small agency components (42.3%) did not establish a policy because they did not
buy or develop telecommunication products.

The following table summarizes the responses
provided by the agency components:

Section 508 Standards on Telecommunication
Products by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
telecommunication product standards

90 (28.3%)

61 (34.3%)

13 (19.1%)

7 (38.9%)

5 (17.9%)

4 (15.4%)

(b) Yes and no,
parts of our components have done this, while others have not

63 (19.8%)

35 (19.7%)

16 (23.5%)

5 (27.8%)

6 (21.4%)

1 (3.8%)

(c) No, but a
timetable was established to do so

41 (12.9%)

18 (10.1%)

5 (7.4%)

3 (16.7%)

7 (25.0%)

8 (30.8%)

(d) No, and
there were no plans to do so

76 (23.9%)

42 (23.6%)

20 (29.4%)

3 (16.7%)

9 (32.1%)

2 (7.7%)

(e) No, we don't
buy or develop telecommunications products

48 (15.1%)

22 (12.4%)

14 (20.6%)

0 (0.0%)

1 (3.6%)

11 (42.3%)

Question
1(d) asked whether agency components established
policies and procedures to comply with the technical requirements for video and
multimedia products in the Section 508 EIT Accessibility Standards. Overall, agency components reported
establishing a policy (26.4%) or parts of their components establishing a
policy (19.2%) to comply with the technical requirements for video and multimedia
products. Another 77 agency components
(24.2%) reported not establishing a policy and had no plans to establish a
policy to comply with the technical requirements for video and multimedia
products. A higher percentage of very
small agency components (46.2%) did not establish a policy because they did not
buy or develop video and multimedia products.

The following table provides the specific
responses by the agency components:

Section 508 Standards on Video/Multimedia
Products by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
video/multimedia product standards

84 (26.4%)

57 (32.0%)

13 (19.1%)

6 (33.3%)

4 (14.3%)

4 (15.4%)

(b) Yes and no,
parts of our components have done this, while others have not

61 (19.2%)

36 (20.2%)

16 (23.5%)

6 (33.3%)

3 (10.7%)

0 (0.0%)

(c) No, but a
timetable was established to do so

43 (13.5%)

19 (10.7%)

3 (4.4%)

3 (16.7%)

10 (35.7%)

8 (30.8%)

(d) No, and
there were no plans to do so

77 (24.2%)

40 (22.5%)

22 (32.4%)

3 (16.7%)

10 (35.7%)

2 (7.7%)

(e) No, we don't
buy or develop video/multimedia products

53 (16.7%)

26 (14.6%)

14 (32.4%)

0 (0.0%)

1 (3.6%)

12 (46.2%)

Question
1(e) asked whether agency components established
policies and procedures to comply with the technical requirements for self
contained, closed products in the Section 508 EIT Accessibility Standards. Overall, agency components reported
establishing a policy (24.5%) or parts of their components establishing a
policy (18.9%) to comply with the technical requirements for self contained,
closed products. Another 68 agency
components (21.4%) reported not establishing a policy and had no plans to
establish a policy to comply with the technical requirements for self
contained, closed products. A higher
percentage of very small agency components (50.0%) did not establish a policy
because they did not buy or develop self contained, closed products.

The agency components’ responses are
summarized in the table below:

Section 508 Standards on Self
Contained, Closed Products by Number (Percent) of Components in
Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
self contained, closed product standards

78 (24.5%)

52 (29.2%)

12 (17.7%)

6 (33.3%)

4 (14.3%)

4 (15.4%)

(b) Yes and no,
parts of our components have done this, while others have not

60 (18.9%)

36 (20.2%)

16 (23.5%)

5 (27.8%)

2 (7.1%)

1 (3.8%)

(c) No, but a
timetable was established to do so

35 (11.0%)

13 (7.3%)

6 (8.8%)

3 (16.7%)

8 (28.6%)

5 (19.2%)

(d) No, and
there were no plans to do so

68 (21.4%)

36 (20.2%)

17 (25.0%)

3 (16.7%)

9 (32.1%)

3 (11.5%)

(e) No, we don't
buy or develop self contained, closed products

77 (24.2%)

41 (23.0%)

17 (25.0%)

1 (5.6%)

5 (17.9%)

13 (50.0%)

Question
1(f) asked whether agency components established
policies and procedures to comply with the technical requirements for desktop
and portable computers in the Section 508 EIT Accessibility Standards. Overall, agency components reported
establishing a policy (35.5%) or parts of their components establishing a
policy (14.5%) to comply with the technical requirements for desktop and
portable computers. Another 87 agency
components (27.4%) reported not establishing a policy and had no plans to
establish a policy to comply with the technical requirements for desktop and
portable computers.

The following table provides the agency components’
responses:

Section 508 Standards on Computers by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
desktop/portable computer standards

113 (35.5%)

73 (64.6%)

19 (27.9%)

7 (38.9%)

7 (25.0%)

7 (26.9%)

(b) Yes and no,
parts of our components have done this, while others have not

The Section 508 EIT Accessibility Standards
contain functional performance requirements that are intended for overall
product evaluation and for technologies or components for which there is no
specific requirement under the technical requirements. In this section, agencies and their components
were asked a question relating to their policies and procedures to comply with
the functional performance requirements of the Section 508 EIT Accessibility
Standards. A total of 318 agency
components participated in this section.

Question
1 asked whether agency components established policies and procedures to
comply with the functional performance requirements of the Section 508 EIT
Accessibility Standards. Overall, 155 agency
components reported establishing a policy (28.3%) or parts of their components
establishing a policy (20.4%) to comply with the functional performance
requirements. Another 106 agency
components (33.3%) reported not establishing a policy and had no plans to
establish a policy to comply with the functional performance requirements. The agency components reported the following:

Functional Performance Criteria by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established to comply with the
functional performance criteria standards

90 (28.3%)

62 (34.8%)

12 (17.6%)

5 (27.8%)

5 (17.9%)

6 (23.1%)

(b) Yes and no,
parts of our components have done this, while others have not

Section 508 EIT Accessibility Standards
require agency components to use alternate formats and alternate methods in
providing individuals with disabilities access to information and documentation
for EIT products. Agencies and their components
were asked to identify the alternate formats and alternate methods used by
their components. In this section,
agency components were allowed to select any number of available
options. Thus, the total of percentages
within each column of the tables may exceed 100%. A total of 318 agency components
participated in this section.

In general, agency components identified
varying demand for each of the available alternate formats and alternate
methods. [15] Overall, website, E-mail, and large print
were the most common alternate formats used by agency components. Braille was the least common alternate
formats used by agency components.
Similarly, website, E-mail, TTY, and sign language were the most common
alternate methods used by agency components.
Mobile texting was the least common alternate methods used by agency
components.

Question
1 explained that Section 508 EIT Accessibility Standards require agency
components to provide product support documentation for EIT products to end
users in alternate formats upon request.
Agency components were asked to identify the alternate formats used by
their components.

A total of 122 agency components (38.4%) were
unable to identify any alternate formats used because they did not track this information. Another 113 agency components (35.5%) could
not identify any alternate formats used because they reported that no requests
were received. In addition, 38 agency
components (11.9%) could not identify any alternate formats used because the
components were not responsible for providing EIT product support. In general, agency components reported
different demand for each of the available alternate formats. Overall, website (21.1%), E-mail (17.3%), and
large print (15.1%) were the most popular alternate formats used by agency
components for EIT product support documentation. By contrast, Braille (8.5%) was the least popular
alternate format used by an agency component.

The following table summarizes
the responses provided by the agency components:

Product Support Documentation Provided
in Alternate Formats by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Braille

27 (8.5%)

16 (9.0%)

3 (4.4%)

5 (27.8%)

1 (3.6%)

2 (7.7%)

(b) ASCII text

36 (11.3%)

23 (12.9%)

7 (10.3%)

2 (11.1%)

3 (10.7%)

1 (3.8%)

(c) Large print

48 (15.1%)

32 (18.0%)

9 (13.2%)

1 (5.6%)

4 (14.3%)

2 (7.7%)

(d) Website

67 (21.1%)

39 (21.9%)

16 (23.5%)

3 (16.7%)

3 (10.7%)

6 (23.1%)

(e) E-mail

55 (17.3%)

31 (17.4%)

13 (19.1%)

3 (16.7%)

3 (10.7%)

5 (19.2%)

(f) CD-ROM/DVD

34 (10.7%)

21 (11.8%)

7 (10.3%)

2 (11.1%)

1 (3.6%)

3 (11.5%)

(g) Recorded
Audio

36 (11.3%)

21 (11.8%)

9 (13.2%)

1 (5.6%)

4 (14.3%)

1 (3.8%)

(h) Other

26 (8.2%)

15 (8.4%)

4 (5.9%)

1 (5.6%)

4 (14.3%)

2 (7.7%)

(i) We did not receive any requests

113 (35.5%)

58 (32.6%)

19 (27.9%)

8 (44.4%)

4 (14.3%)

13 (50.0%)

(j) We did not
track this data

122 (38.4%)

73 (41.0%)

28 (27.9%)

6 (33.3%)

4 (14.3%)

4 (15.4%)

(k) N/A, we were
not responsible for our own EIT product support

38 (11.9%)

21 (11.8%)

12 (17.6%)

0 (0.0%)

0 (0.0%)

13 (50.0%)

Question
2 explained that Section 508 EIT Accessibility
Standards require agency components to provide access to descriptions of the
accessibility and compatibility features of EIT products to end users in
alternate formats or alternate methods upon request. Agency components were asked to identify the
alternate formats and alternate methods used by their components.

A total of 128 agency components (40.3%) were
unable to identify any alternate formats used because they did not track this
information. Another 119 agency
components (37.4%) could not identify any alternate formats used because they
reported that no requests were received.
In addition, 35 agency components (11.0%) could not identify any
alternate formats used because the components were not responsible for
providing EIT product support. Agency
components’ responses to this question were very similar to the responses in
Question 1. Again, website (18.9%),
E-mail (17.3%), and large print (13.5%) were the most common alternate formats
used by agency components for descriptions of EIT accessibility features. Braille (7.2%) was the least common alternate
format used by an agency component. The
following table provides the specific responses by the agency components:

In addition, a total of 120 agency components
(37.7%) were unable to identify any alternate methods used because they did not
track this information. Another 102
agency components (32.1%) could not identify any alternate methods used because
they reported that no requests were received.
Thirty-five agency components (11.0%) could not identify any alternate
methods used because the components were not responsible for providing EIT
product support. In general, while
reported responses varied among agency size categories, providing information
by website (19.8%), E-mail (18.2%), TTY (17.0%), sign language (17.0%), and
voice (15.1%) were reported to be the most popular options. By contrast, mobile texting (5.7%) was the
least popular alternate method used by an agency component.

Question
3 explained that Section 508 EIT Accessibility Standards require agency
components to accommodate the communication needs of end users with
disabilities when providing support services for EIT products. Agency components were asked to identify the types
of accommodations used by their components.

A total of 111 agency components (34.9%) were
unable to identify any types of accommodations used because they did not track
this information. Another 89 agency
components (28.0%) could not identify any types of accommodations used because
they reported that no requests were received.
In addition, 31 agency components (9.7%) could not identify any types of
accommodations used because the components were not responsible for providing
EIT product support. In general, agency
components reported different demand for each of the available types of accommodations. Overall, E-mail (28.9%), website (28.0%), and
voice (26.1%) were the most common types of accommodations used by agency components. By contrast, mobile texting (7.2%) was the
least common type of accommodation used by an agency component.

Agencies and their components were asked questions
regarding the Section 508 training of various employees in their
workforce. A total of 318 agency
components participated in this section.
However, 187 agency components did not complete this section because
they did not offer Section 508 training to their employees.

The following provides a brief summary of the
agency components’ responses:

Agency components that offered training reported that Section 508
coordinators, purchase card holders, and website developers were the three
most often identified employees to receive mandatory Section 508 training.

Agency components that offered training reported providing the most
average hours of training to Section 508 coordinators (a little more than
four hours) and the fewest average hours of training to IT help desk staff
(less than one hour). Very small
agency components reported the highest number of average hours of Section
508 training for many of the available types of employees.

Sixty-seven
percent of agency components that offered training reported online
training as the most common method for providing Section 508 training. By contrast, mid-size agency components reported classroom instruction and
conferences as their most common method for providing Section 508
training.

A majority of
agency components that offered training reported Section 508 statute,
Section 508 EIT Accessibility Standards, and procurement of accessible EIT
among the three most common subject areas covered by their Section 508
training. Captioning was the least
common subject area covered by agency components’ Section 508 training.

Question
1 asked whether agency components provided Section 508 training to their
employees. Those agency components that
did not offer Section 508 training to their employees were asked to skip the
remaining questions in this section and proceed to the next section regarding
the Section 508 Challenges. Across all
agency size categories, a majority of agency components (58.8%) reported not
providing Section 508 training to their employees. A higher percentage of small (82.1%) and very
small agency components (80.8%) reported not providing Section 508
training. A total of 131 agency
components (41.2%) reported providing Section 508 training to their employees.

The agency
components reported the following:

Section 508 Training Provided by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, Section 508 training was provided

131 (41.2%)

84 (47.2%)

26 (38.2%)

11 (61.1%)

5 (17.9%)

5 (19.2%)

(b) No

187 (58.8%)

94 (52.8%)

42 (61.8%)

7 (38.9%)

23 (82.1%)

21 (80.8%)

Question
2 asked whether Section 508 training was mandatory for any employees in
the agency components’ workforce. This
question permitted agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%. A
total of 131 agency components that offered Section 508 training
responded to this survey question. Overall,
agency components reported that Section 508 coordinators (42.0%), purchase card
holders (27.5%), and website developers (26.0%) were the three most often
identified employees to receive mandatory Section 508 training. By contrast, IT help desk staff (8.4%), video
and multimedia developers (9.9%), and program managers (9.9%) were the three
least often identified employees to receive mandatory Section 508
training. Interestingly, 10 agency
components (7.6%) reported providing mandatory Section 508 training to all of
their employees, and 40 agency components (30.5%) reported not requiring Section
508 training for any of their employees.

The following table summarizes the responses
provided by the agency components:

Mandatory Section 508 Training by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Section 508 coordinators

55 (42.0%)

40 (47.6%)

9 (34.6%)

2 (18.2%)

2 (40.0%)

2 (40.0%)

(b) Requiring
officials

19 (14.5%)

14 (16.7%)

4 (15.4%)

1 (9.1%)

0 (0.0%)

0 (0.0%)

(c) Program
managers

13 (9.9%)

11 (13.1%)

2 (7.7%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(d) COTR/COR

26 (19.8%)

18 (21.4%)

5 (19.2%)

2 (18.2%)

0 (0.0%)

1 (20.0%)

(e) Contracting
officers

28 (21.4%)

21 (25.0%)

4 (15.4%)

2 (18.2%)

0 (0.0%)

1 (20.0%)

(f) Purchase
cardholders

36 (27.5%)

29 (34.5%)

3 (11.5%)

3 (27.3%)

0 (0.0%)

1 (20.0%)

(g) Software
developers

18 (13.7%)

12 (14.3%)

5 (19.2%)

1 (9.1%)

0 (0.0%)

0 (0.0%)

(h) Website
developers

34 (26.0%)

20 (23.8%)

8 (30.8%)

4 (36.4%)

0 (0.0%)

2 (40.0%)

(i) Video and multimedia developers

13 (9.9%)

9 (10.7%)

3 (11.5%)

0 (0.0%)

0 (0.0%)

1 (20.0%)

(j) IT help desk
staff

11 (8.4%)

8 (9.5%)

2 (11.5%)

1 (9.1%)

0 (0.0%)

0 (0.0%)

(k) Other
employees

14 (10.7%)

7 (8.3%)

3 (11.5%)

4 (36.4%)

0 (0.0%)

1 (20.0%)

(l) All
employees

10 (7.6%)

6 (7.1%)

1 (3.8%)

0 (0.0%)

0 (0.0%)

3 (60.0%)

(m) No employees

40 (30.5%)

20 (23.8%)

12 (46.2%)

4 (36.4%)

3 (60.0%)

1 (20.0%)

Questions
3 - 10 asked agency components for information on Section
508 training for various employees in their workforce. Specifically, agency components were
requested to provide the number of hours of annual Section 508 training for
various employees. Agency components
reported providing the most average hours of training to Section 508
coordinators (4.2 hours). By contrast,
agency components reported providing the fewest average hours of training to IT
help desk staff (0.6 hours). For most
agency components, with the exception of Section 508 coordinators, the average
hours of Section 508 training for all available types of employees was slightly
below or slightly above one hour.
Surprisingly, very small agency components reported the highest number
of average hours of Section 508 training for many of the available types of
employees. For example, very small
agency components reported providing 5.2 average hours of training to website
developers, which was more than three times the average hours provided by all
agency components.

The following table provides the specific
responses by the agency components:

Section 508 Training Provided to
Personnel by Number (Percent) of Components in Differently-Sized Agencies

Question
11 asked agency components to identify their methods
for providing Section 508 training. In
this question, agency components were allowed to select any number of available
options. Thus, the total of percentages
within each column of the tables may exceed 100%. In general, agency components identified
various methods for providing Section 508 training. With the exception of small agencies, components
reported online training (67.2%) as the most common method for providing
Section 508 training to their employees.
Mid-size agency components reported classroom instruction (81.8%) and
conferences (72.7%) as their most common method for providing Section 508
training.

The agency components’ responses are
summarized in the table below:

Section 508 Training Methods by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Section 508 universe (www.section508.gov)

68 (51.9%)

41 (48.8%)

14 (53.8%)

7 (63.6%)

3 (60.0%)

3 (60.0%)

(b) Other online
training

88 (67.2%)

60 (71.4%)

17 (65.4%)

7 (63.6%)

1 (20.0%)

3 (60.0%)

(c) Classroom
instruction

71 (54.2%)

42 (50.0%)

16 (61.5%)

9 (81.8%)

2 (40.0%)

2 (40.0%)

(d) Conferences
and seminars

72 (55.0%)

44 (52.4%)

14 (53.8%)

8 (72.7%)

3 (60.0%)

3 (60.0%)

(e) Other

54 (41.2%)

32 (38.1%)

15 (57.7%)

3 (27.3%)

2 (40.0%)

2 (40.0%)

Question
12 asked agency components to identify specific subject
areas covered by their Section 508 training.
This question permitted agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%.
Overall, a majority of agency components reported Section 508 statute
(80.2%), Section 508 EIT Accessibility Standards (79.4%), and procurement of accessible
EIT (60.3%) as the three most common subject areas covered by their Section 508
training. Captioning was the least
common subject area covered by agency components’ Section 508 training.

The agency components’ responses are
summarized in the table below:

Section 508 Training Subject Matter by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Section 508 law

105 (80.2%)

66 (78.6%)

23 (88.5%)

9 (81.8%)

3 (60.0%)

4 (80.0%)

(b) Section 508
EIT Accessibility Standards

104 (79.4%)

66 (78.6%)

23 (88.5%)

9 (81.8%)

3 (60.0%)

3 (60.0%)

(c) How to buy
accessible EIT

79 (60.3%)

52 (61.9%)

17 (65.4%)

5 (45.5%)

1 (20.0%)

4 (80.0%)

(d) How to
create accessible software

55 (42.0%)

37 (44.0%)

11 (42.3%)

4 (36.4%)

2 (40.0%)

1 (20.0%)

(e) How to
create accessible website

70 (53.4%)

43 (51.2%)

14 (53.8%)

7 (63.6%)

2 (40.0%)

4 (80.0%)

(f) How to
create accessible electronic forms

65 (49.6%)

38 (45.2%)

14 (53.8%)

6 (54.5%)

3 (60.0%)

4 (80.0%)

(g) How to
create accessible electronic documents

73 (55.7%)

44 (52.4%)

16 (61.5%)

7 (63.6%)

3 (60.0%)

3 (60.0%)

(h) How to
create accessible .pdfs

75 (57.3%)

44 (52.4%)

15 (57.7%)

7 (63.6%)

5 (100.0%)

4 (80.0%)

(i) How to caption video or multimedia

45 (34.4%)

29 (34.5%)

10 (38.5%)

2 (18.2%)

3 (60.0%)

2 (40.0%)

(j) How to
evaluate software, websites, or documents for accessibility

Agencies and their components were asked a
question regarding challenges in implementing and complying with
Section 508. A total of 318 agency
components participated in this section.

Question
1 asked agency components to identify challenges in implementing and
complying with Section 508. In this
question, agency components were allowed to select any number of available
options. Thus, the total of percentages
within each column of the tables may exceed 100%. In general, many agency components reported lack
of resources (58.2%), lack of general awareness (50.0%), and lack of training
(43.4%) as the three most common challenges in implementing and complying with Section
508. By contrast, lack of management
support (17.9%) was the least common challenge.
Interestingly, 49 agency components (15.4%) could not identify any
challenges in implementing and complying with Section 508.

The following
table provides the agency components’ responses:

Section 508 Challenges by Number (Percent)
of Components in Differently-Sized Agencies

Section 504 of the Rehabilitation Act prohibits
discrimination on the basis of disability in any program or activity that
receives financial assistance from any federal agency. This means recipients of federal financial
assistance must provide individuals with disabilities an opportunity to participate
in and benefit from aids, benefits and services that are equal to and as
effective as that provided to individuals without disabilities. Today, due to advances in technology,
recipients of federal financial assistance may provide benefits and services
via websites and other EITs. In this
section, agencies and their components were asked questions regarding their policies
of requiring recipients of federal financial assistance to ensure accessibility
of their websites and other EITs. A
total of 318 agency components participated in this section. However, 195 agency components did not
complete this section because they did not provide any federal financial
assistance to recipients.

The following provides a brief summary of the
agency components’ responses:

Nearly forty percent of agency components that provided federal financial
assistance reported not having any knowledge whether recipients of federal
financial assistance were required to ensure accessibility of websites and
other EITs. Another twenty-four
percent of agency components did not require recipients to ensure
accessibility of websites and other EITs.
Thirty-five percent of agency components required recipients or parts
of their components required recipients to ensure accessibility of websites
and other EITs.

Among the agency components that required recipients to
ensure accessibility of EITs, a majority reported that they used the Section
508 EIT Accessibility Standards as the standard for compliance by recipients of
federal financial assistance.

Among the agency components that required recipients to
ensure accessibility of EITs, a majority reported that they had established an EIT accessibility policy or parts of
their components had established an EIT accessibility policy for
recipients of federal financial assistance.

Question
1 asked whether agency components required recipients of federal
financial assistance to ensure accessibility of websites and other EITs. Those agency components that did not require
recipients to ensure accessibility of EITs were asked to skip the remaining
questions in this section and proceed to the next section regarding Procurement. Overall, 22 agency components (39.8%)
reported not having any knowledge whether recipients of federal financial assistance
were required to ensure accessibility of EITs.
Another 44 agency components reported requiring recipients (17.9%) or
parts of their components requiring recipients (17.9%) to ensure accessibility
of EITs. Twenty-five agency components (20.3%)
did not require and had no plans to require recipients of federal financial
assistance to ensure accessibility of EITs.

The agency components reported the following:

EIT Accessibility Under
Section 504 by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, recipients of federal financial assistance were required to
provide accessible websites and other EITs

22 (17.9%)

9 (12.7%)

5 (19.2%)

4 (57.1%)

0 (0.0%)

4 (36.4%)

(b) Yes and no,
parts of our components have done this, while others have not

22 (17.9%)

14 (19.7%)

4 (15.4%)

2 (28.6%)

2 (25.0%)

0 (0.0%)

(d) No, but a
timetable was established to do so

5 (4.1%)

3 (4.2%)

0 (0.0%)

0 (0.0%)

1 (12.5%)

1 (9.1%)

(e) No, and
there were no plans to do so

25 (20.3%)

14 (19.7%)

4 (15.4%)

0 (0.0%)

2 (25.0%)

5 (45.5%)

(c) Don't know

49 (39.8%)

31 (43.7%)

13 (50.0%)

1 (14.3%)

3 (37.5%)

1 (9.1%)

Question
2 asked agency components to identify EIT standards or guidelines used by
recipients of federal financial assistance to ensure accessibility of their websites
and other EITs. A total of 44 agency components that
required recipients to ensure accessibility of their EITs responded to this
survey question. Overall, 29 agency
components (65.9%) reported the Section 508 EIT Accessibility Standards as the
most common standard used by recipients of federal financial assistance. Another 10 agency components (22.7%) reported
the Web Content Accessibility Guidelines as the second most common standard
used by recipients of federal financial assistance. The following table summarizes the responses
provided by the agency components:

EIT Standards Used Under Section 504 by
Number (Percent) of Components in Differently-Sized Agencies

Procurement policies and practices are
critically important to an agency component’s compliance with Section 508
for two reasons. First, Section 508 authorizes
civil actions and administrative complaints by persons with disabilities when
federal departments and agencies procure electronic and information technology that
is not compliant with the Section 508 EIT Accessibility Standards. [16] Second, the Federal Acquisition Regulation
(FAR) was amended to incorporate the Section 508 EIT Accessibility Standards,
and the amendment became effective on June 25, 2001.

The procurement section of the survey focused
on five areas:

Contract Requirements

Market Research

Decision Documentation

Exceptions and Commercial Non-Availability
Determinations

Pre or Post Award Protests

The following provides a brief summary of
findings for each of the five subsections of Section III – Procurement.

Contract Requirements. Agency components most often relied on basic contract requirements (such as general language requiring Section 508 compliance). Also, agency components most often relied on reviewing the materials the vendor submitted rather than actual product testing to validate Section 508 compliance.

Market Research. Agency components reported that the two most popular means of conducting market research were via internet research and vendor information (e.g., Voluntary Product Accessibility Template[17] or Government Product Accessibility Template).

Decision Documentation. Agency components most often conveyed
their decisions regarding Section 508 applicability or exceptions on
EIT procurements in writing.
However, only a small number of agency components have established
formalized systems for tracking and documenting Section 508 decisions.

Exceptions and Commercial
Non-Availability Determinations. Nearly forty percent of agency
components reported establishing a formal, written policy to document
Section 508 exceptions claimed on EIT procurements. Many of these agency components reported
that their EIT procurements met the Section 508 requirements and that reliance on an
exception was unnecessary. Agencies made occasional use of the available
exceptions and reported most frequently using the exception for products
located in non-occupiable locations. [18] Where an undue burden determination was
necessary, forty-six percent of agency
components required approval at the top agency or top component level,
while nearly twenty percent of agency components allowed the contracting
official to make undue burden determinations without higher approval.

Pre or Post Award Protests. One component in a very large agency reported
receiving and sustaining one procurement protest based on Section 508.

Agencies and their components were asked questions
relating to how Section 508 requirements were met in their EIT
procurements. This section included
specific questions covering the initial contract process through the assessment
of deliverables. A total of 318 agency
components participated in this section.
However, 57 agency components did not complete this section because they
were not responsible for EIT procurements.

In general, agency components reported reliance on simple Section 508 tools, such as standard clauses and basic conformance materials from vendors. Seventy percent of agency components reported using general language requiring Section 508 compliance as the most common means of incorporating Section 508 requirements in their solicitations. Sixty percent of agency components reported reviewing the materials vendor submitted as the most common means of evaluating EIT related deliverables. Surprisingly, a small number of agency components reported not incorporating Section 508 requirements in their solicitations, and not conducting any evaluation before accepting EIT related deliverables.

Question
1 asked how agency components incorporated Section 508 requirements in
their solicitations that contained EIT related deliverables. Those agency components that did not
incorporate Section 508 requirements in their solicitations were asked to skip
the remaining questions in this section and proceed to the next section
regarding Market Research. This question
permitted agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%.

Across all agency size categories, general language requiring Section 508 compliance was the most common means of incorporating Section 508 requirements in their solicitations, used by 184 agency components (70.5%). Specific applicable requirements from Section 508 EIT Accessibility Standards were the second most common means of incorporating Section 508 requirements in their solicitations, used by 125 agency components (47.9%). VPATs were the least common method of incorporating Section 508 requirements in their solicitations, used by 75 agency components (28.7%). Surprisingly, 20 agency components (7.7%) did not incorporate Section 508 requirements in their solicitations for EIT procurements.

The agency components’ responses are
summarized in the table below:

Section 508 Incorporation Methods by
Number (Percent) of Components in Differently-Sized Agencies

Question 3 asked agency components how they identified contract requirements for test and
acceptance of EIT related deliverables of applicable Section 508 EIT
Accessibility Standards. This
question permitted agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%. A
total of 241 agency components responded to this survey question. Results varied between agency
components regarding their reported use of testing. Overall, the option most often selected by
agency components across all size categories was to review the materials
submitted. Surprisingly, 43 agency
components (17.8%) reported that they conducted no evaluation at all.

The agency components reported the following:

Testing Methods by Number (Percent) of
Components in Differently-Sized Agencies

Agencies and their components were asked a
question relating to market research in complying with Section 508 for EIT procurements. A total of 318 agency components participated
in this section. However, 57 agency
components did not complete this section because they were not responsible for EIT
procurements.

Question
1 asked agency components how they performed market research for
procurements that contain EIT related deliverables. This question permitted agency components to select any number of
available options. Thus, the total of
percentages within each column of the tables may exceed 100%. In general, there was little variation among
agency size categories regarding their choices.
A majority of agency components (75.5%) reported that internet research
was the most common method of performing market research. A total of 171 agency components (65.5%)
reported vendor information as the second most common method of performing
market research. By contrast, internal
database of products was the least common method of performing market research. Twenty-eight agency components (10.7%)
reported that they performed no market research at all when procuring EIT
products. The following table summarizes
the responses provided by the agency components:

Market Research Source by Number
(Percent) of Components in Differently-Sized Agencies

Agencies and their components were asked
questions relating to their methods to document decisions regarding Section 508
applicability or exceptions on EIT procurements. A total of 318 agency components participated
in this section. However, 57 agency components
did not complete this section because they were not responsible for EIT
procurements.

In general, a majority of agency components
reported that requiring officials convey their decisions regarding Section 508
applicability or exceptions on EIT procurements in writing. However, twenty-one percent of agency
components reported that they did not document decisions at all. In addition, a small number of agency
components reported using an electronic system for tracking and documenting
Section 508 decisions.

Question
1 asked agency components how their requiring officials document
decisions when determining Section 508 applicability or exceptions on EIT
procurements. This question permitted
agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%.
Overall, a majority of agency components (74.7%) reported that requiring
officials convey their decisions regarding Section 508 in writing. This was particularly true within larger agency
components. Small and very small agency
components reported using oral communications more frequently than larger
agency components. Fifty-seven agency
components (21.8%) reported that they did not document any decisions when
determining Section 508 applicability or exceptions on EIT procurements.

The following table provides the specific
responses by the agency components:

Decision Documentation Methods by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) By written notice (specific form required)

96 (36.8%)

71 (48.6%)

14 (26.4%)

4 (22.2%)

4 (16.0%)

3 (15.8%)

(b) By written
notice (form not required)

99 (37.9%)

46 (31.5%)

26 (49.1%)

9 (50.0%)

10 (40.0%)

8 (42.1%)

(c) By oral
communication

47 (18.0%)

21 (14.4%)

9 (17.0%)

3 (16.7%)

9 (36.0%)

5 (26.3%)

(d) Other

42 (16.1%)

27 (18.5%)

9 (17.0%)

2 (11.1%)

4 (16.0%)

0 (0.0%)

(e) Did not
document decisions

57 (21.8%)

27 (18.5%)

13 (22.8%)

4 (22.2%)

6 (24.0%)

7 (36.8%)

Question
2 inquired whether agency components were required to document decisions
regarding Section 508 applicability or exceptions for EIT purchases of $3,000
or less (i.e. , micro-purchases). A total
of 204 agency components that documented decisions on EIT procurements
responded to this survey question. In
general, a slight majority of agency components (51.0%) reported requiring
decision documentation for EIT micro-purchases.

The agency components’ responses are
summarized in the table below:

Decision Documentation for
Micro-Purchases by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, we document decisions for EIT micro-purchases

104 (51.0%)

68 (57.1%)

16 (40.0%)

6 (42.9%)

9 (47.4%)

5 (41.7%)

(b) No

100 (49.0%)

51 (42.9%)

24 (60.0%)

8 (57.1%)

10 (52.6%)

7 (58.3%)

Question
3 asked whether agency components track their decision documentation regarding
Section 508 applicability or exceptions for EIT procurements. Those agency components that did not track
their decision documentation were asked to skip the remaining questions in this
section and proceed to the next section regarding Exceptions and Commercial
Non-Availability Determinations. Overall,
a majority of agency components (56.9%) reported that they did not track their decision
documentation regarding Section 508 applicability or exceptions for EIT
procurements. A higher percentage of
small agency components (78.9%) did not track their decision documentation.

The following table provides the agency components’
responses:

Decision Documentation Tracking by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, we track document decisions for EIT purchases

88 (43.1%)

56 (47.1%)

18 (45.0%)

5 (35.7%)

4 (21.1%)

5 (41.7%)

(b) No

116 (56.9%)

63 (52.9%)

22 (55.0%)

9 (64.3%)

15 (78.9%)

7 (58.3%)

Question 4 inquired whether agency components established an automated system for tracking and documenting decisions regarding Section 508 applicability or exceptions for EIT procurements. A total of 88 agency components that tracked their decision documentation responded to this survey question. In general, a majority of agencies (59.1%) reported that they did not have an automated system available for specifically tracking Section 508 applicability or exceptions for EIT procurements. Only 36 agency components (40.9%) reported having an electronic system for tracking and documenting Section 508 decisions.

The agency components reported the following:

Automated Decision Documentation
Tracking System by Number (Percent) of Components in Differently-Sized Agencies

Agencies and their components were asked
questions relating to their use of Section 508 exceptions on EIT
procurements. A total of 318 agency
components participated in this section.
However, 57 agency components did not complete this section because they
were not responsible for EIT procurements.

In general, nearly forty percent of agency
components established a formal, written policy to document Section 508
exceptions claimed on EIT procurements.
Many of these agency components reported EIT products they procured fully met the Section 508
requirements and that reliance on an exception was unnecessary. Where an exception was used, the exception most frequently claimed by
agency components was the exception for product located in non-occupiable locations. [19] The exception least frequently claimed by
agency components was the exception for undue burden. In addition, with regard to the level of
review required for undue burden determinations – forty-six percent of agency
components required approval at the top agency or top component level, while
nearly twenty percent of agency components allowed the requiring or procurement official to
make undue burden determinations without higher approval.

Question
1 asked whether agency components established a formal, written
policy to document any Section 508 exceptions claimed on EIT procurements. Those agency components that did
not establish a policy were asked to skip the remaining questions in this
section and proceed to the next section regarding Administrative Complaints and
Civil Actions. Overall, a majority of
agency components (60.9%) reported that they did not establish a policy to
document Section 508 exceptions claimed on EIT procurements.

The following table summarizes the responses
provided by the agency components:

Decision Documentation Policy by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written policy was established

102 (39.1%)

73 (50.0%)

14 (26.4%)

6 (33.3%)

5 (20.0%)

4 (21.1%)

(b) No

159 (60.9%)

73 (50.0%)

39 (73.6%)

12 (66.7%)

20 (80.0%)

15 (78.9%)

Question
2 asked agency components to identify the types of Section 508
exceptions claimed on EIT procurements. This
question permitted agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%. A
total of 102 agency components that established a policy to document Section
508 exceptions responded to this survey question. In general, 38 agency components (37.3%)
reported that EIT products they procured fully met the Section 508 requirements
and that reliance on an exception was unnecessary. The exception most frequently claimed by
agency components (32.4%) was the exception for product located in
non-occupiable locations. The exception least frequently claimed by
agency components (10.8%) was the exception for undue burden.

The following table provides the specific
responses by the agency components:

Exceptions Used by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Undue burden

11 (10.8%)

8 (11.0%)

3 (21.4%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(b) Determination of commercial non-availability

32 (31.4%)

24 (32.9%)

6 (42.9%)

0 (0.0%)

0 (0.0%)

2 (50.0%)

(c) National security

14 (13.7%)

14 (19.2%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(d) Product
was to be acquired by a contractor incidental to a contract

15 (14.7%)

13 (17.8%)

2 (14.3%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(e) Fundamental alteration

19 (18.6%)

15 (20.5%)

4 (21.1%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(f) Product
to be located in space frequented only by service personnel for maintenance,
repair, or occasional monitoring

33 (32.4%)

26 (35.6%)

2 (14.3%)

1 (16.7%)

2 (40.0%)

2 (50.0%)

(g) No
exception used

38 (37.3%)

24 (32.9%)

7 (50.0%)

4 (66.7%)

3 (60.0%)

0 (0.0%)

(h) Don't
know

18 (17.6%)

15 (20.5%)

1 (7.1%)

1 (16.7%)

0 (0.0%)

1 (25.0%)

Question
3 asked agency components to identify the minimal level of administrative
approval for an undue burden exception on EIT procurements. Overall, 47 agency components (46.0%)[20] reported requiring approval at the top agency or top component level. Twenty agency components (19.6%) reported
that the requiring or procurement official could make the undue burden determination
without additional approval.

Specifically, the agency components’ provided
the following responses:

Minimal
Level of Approval for Undue Burden Exception by Number (Percent) of Components in Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) An approving
official or board at the agency level

23 (22.5%)

18 (24.7%)

2 (14.3%)

0 (0.0%)

1 (20.0%)

2 (50.0%)

(b) An
approving official or board at each component of the agency

24 (23.5%)

18 (24.7%)

4 (28.6%)

1 (16.7%)

1 (20.0%)

0 (0.0%)

(c) An
approving official or board below the component level

7 (6.9%)

5 (6.8%)

1 (7.1%)

0 (0.0%)

0 (0.0%)

1 (25.0%)

(d) Requiring or procurement official without additional approval

20 (19.6%)

13 (17.8%)

2 (14.3%)

3 (50.0%)

1 (20.0%)

1 (25.0%)

(e) Section
508 coordinator

16 (15.7%)

10 (13.7%)

4 (28.6%)

1 (16.7%)

1 (20.0%)

0 (0.0%)

(f) Other

12 (11.8%)

9 (12.3%)

1 (7.1%)

1 (16.7%)

1 (20.0%)

0 (0.0%)

Question
4 is similar to Question 3, except agency components were asked to
identify the minimal level of administrative approval for all exceptions other
than undue burden. Agency components
reported a less stringent approval process for exceptions other than undue
burden. Overall, almost one and a half
times as many agency components (29.4% versus 19.6%) permitted the requiring or
procurement officer to make the exceptions determination alone. Only 27 agency components (26.5%) reported
requiring approval at the top agency or top component level.

Agencies and their components were asked questions
relating to protests on EIT procurements.
A total of 102 agency components that established a decision
documentation policy responded to the survey questions. The agency components’ responses
are summarized below:

Questions 1 and 2 asked whether agency components received any procurement
protests, and if so, to estimate the number of procurement protests filed
claiming that the component did not properly follow the requirements of
Section 508. One very large agency
component reported receiving one procurement protest based on Section 508.

Questions 3 and 4 asked whether agency components sustained any procurement protests,
and if so, to estimate the number of procurement protests sustained based
on Section 508 related issues. One
very large agency component reported sustaining one procurement protest
based on Section 508.

Persons with disabilities can file
administrative complaints or civil lawsuits on or after June 21, 2001. 29 U.S.C. § 794d(f)(1)(B). Section 794d(f)(1(B)
provides:

This
subsection shall apply only to electronic and information technology that is
procured by a Federal department or agency not less than 6 months after the
date of publication by the Access Board of final standards described in
subsection (a)(2). [21]

By statute, persons with disabilities who file
administrative complaints alleging that an agency’s procurement has violated Section
508 must file it with the agency alleged to be in noncompliance. 29 U.S.C. § 794d(f)(2). Specifically, section 794d(f)(2)
provides:

Complaints
filed under paragraph (1) shall be filed with the Federal department or agency
alleged to be in noncompliance. The
Federal department or agency receiving the complaint shall apply the complaint
procedures established to implement section 794 of this title for resolving
allegations of discrimination in a federally conducted program or activity.

This section of the survey focused on
administrative complaints and civil actions related to Section 508 within the
agency components. Two specific areas
were analyzed:

Policies and procedures for processing Section 508 complaints

Number of complaints and civil actions

The following provides a brief summary of
findings for Section IV – Administrative Complaints and Civil Actions.

Policies and Procedures for Processing Section 508 Complaints. Slightly more than thirty
percent of agency components had already established an appropriate set of
policies and procedures specifically to process Section 508
complaints. Fifty-seven percent of
the agency components were either using existing Section 504 complaint
processes or some other process. Also,
a majority of agency components reported success at incorporating ADR into
their complaint processes, and about half of the agency components widely
disseminated complaint filing information on their website.

Number of complaints and civil actions. Agency components reported that 140
administrative complaints and seven civil actions were filed against
agency components alleging a violation of Section 508. [23] Most of the administrative complaints
and civil action were filed against very large and large agency
components.

Agencies and their components were asked
questions regarding their policies and procedures for processing complaints
under Section 508. A total of 318 agency
components participated in this section.
However, 128 agency components did not complete this section because
they were not responsible for receiving or processing their own administrative
complaints under the Rehabilitation Act.

In general, slightly more than thirty percent of
agency components had already established an appropriate set of policies and
procedures specifically to process Section 508 complaints. Fifty-seven percent of the agency components
were either using existing Section 504 complaint processes or some other
process. Also, a majority of agency
components reported success at incorporating ADR into their complaint processes,
and about half of the agency components widely disseminated complaint filing
information on their website.

ADR Incorporation by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, existing complaint process includes ADR

131 (68.9%)

82 (74.5%)

14 (58.3%)

11 (78.6%)

16 (64.0%)

8 (47.1%)

(b) Yes and no,
parts of our components have done this, while others have not

13 (6.8%)

7 (6.4%)

4 (16.7%)

0 (0.0%)

2 (8.0%)

0 (0.0%)

(c) No, but a timetable
was established to do so

9 (4.7%)

4 (3.6%)

0 (0.0%)

1 (7.1%)

3 (12.0%)

1 (5.9%)

(d) No, and there were no plans to do so

37 (19.5%)

17 (15.5%)

6 (25.0%)

2 (14.3%)

4 (16.0%)

8 (47.1%)

Question
3 asked whether agency components widely disseminated, on their website,
instructions to the public and to employees regarding how to file
administrative complaints under Section 508.
Generally, about half of the agency components widely disseminated
complaint filing information to the public and to employees. A total of 84 agency components (44.2%)
reported widely disseminating complaint filing information on their
website. By contrast, 86 agency
components (45.2%) reported not disseminating complaint filing information on
their website.

The following table summarizes the responses
provided by the agency components:

Complaint Filing Information
Availability by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, information was available on our website for the public and
employees

84 (44.2%)

51 (46.4%)

13 (54.2%)

8 (57.1%)

7 (28.0%)

5 (29.4%)

(b) Yes and no, information
was available for the public but not employees

6 (3.2%)

5 (4.5%)

0 (0.0%)

0 (0.0%)

1 (4.0%)

0 (0.0%)

(c) Yes and no,
this information was available for employees but not for the public

Agencies and their components were asked
questions regarding administrative complaints or civil actions filed against
the components alleging a violation of Section 508. A total of 318 agency components participated
in this section. However, 187 agency
components did not complete this section because they did not offer Section 508
training to their employees.

Question
1 - 5 asked agency components to estimate the number of administrative
complaints and civil actions filed, assessed, and resolved. Agency components were asked to answer the following
questions using information
since June 21, 2001, the effective date of the Section 508 EIT Accessibility
Standards. Overall, agency components
reported that 140 administrative complaints and seven civil actions were filed
against agency components alleging a violation of Section 508. Most of the administrative complaints and
civil action were filed against very large and large agency components.

The following table summarizes the responses
provided by the agency components:

Administrative Complaints and Civil
Actions by Number (Percent) of Components in Differently-Sized Agencies

This section of the survey focused on policies
and practices established by agency components to ensure accessibility of their
websites. This section also was designed
to evaluate whether an agency component’s web pages, web-based forms, and
web-based applications were accessible to people with disabilities. Specifically, this section was divided into
two areas concerning website compliance:

Web Policies and Practices

Four Representative Web Pages

The following provides a general summary of
findings for Section V – Website Compliance.

Web Policies and Practices. Nearly ninety percent of agency
components reported having control over their website development and
maintenance, and seventy percent of these agency components reported
establishing formal, written web accessibility policies. Agency components also reported that
Adobe Acrobat (.pdf) files and video and audio
multimedia content were the most frequently used content on their
websites, and a majority of agency components reported that their web accessibility
policies addressed the use of Adobe Acrobat (.pdf)
files and video and audio multimedia content. In addition, almost fifty-eight percent
of agency components reported performing routine automated and/or manual
evaluation and remediation on their websites.

Four Representative Web Pages. Agency components reported that their web
pages, web-based forms, and web-based applications were generally
accessible to persons with disabilities.
A majority of agency components reported success in using alternative
text attribute or other descriptive elements to represent non-text
elements (images). Also, a majority
of agency components reported success in identifying row and column
headers for data tables and associating data and header cells. A majority of agency components reported
that their forms permitted users of assistive technology to access the
information, field elements, and functionality required for completion and
submission of the form. In
addition, a majority of agency components reported that their applications
provided sufficient information about user interface elements (such as
check boxes, radio buttons, menus, toolbars, dialog and popup windows and
controls) to assistive technology. Agency
components did, however, report some difficulty in providing captioning,
audio description, and keyboard accessibility.

Agencies and their components were asked
questions regarding their policies and practices for ensuring that their
websites are accessible to people with disabilities. A total of 318 agency components participated
in this section. However, ten agency
components did not complete this section because they did not have a website.

The following provides a brief summary of the
agency components’ responses:

Agency components reported that Adobe Acrobat (.pdf)
files and video and audio multimedia content were the most frequently used
content on their websites, and a majority of agency components
reported that their web accessibility policies addressed the use of Adobe
Acrobat (.pdf) files and video and audio
multimedia content.

Almost
fifty-eight percent of agency components reported performing routine
automated and/or manual evaluation and remediation on their websites. Specifically, twenty-eight percent of
agency components performed both automated and manual evaluation, while
twenty-four percent of agency components performed only manual evaluation,
and six percent of agency components performed only automated evaluation.

Nearly seventy-three percent of agency components reported designating
and widely advertising e-mail addresses on their websites to allow people
with disabilities to inform the agency components of accessibility
problems encountered on their websites.

Question
1 asked whether agency components have a website. While 96.9% of all agency components did have
a website, 3.1% did not.

The agency components reported the following:

Website by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, we have a website

308 (96.9%)

176 (98.9%)

66 (97.1%)

18 (100.0%)

26 (92.9%)

22 (84.6%)

(b) No

10 (3.1%)

2 (1.1%)

2 (2.9%)

0 (0.0%)

2 (7.1%)

4 (15.4%)

Question
2 asked whether agency components created and/or maintained their own websites. While most agency components (89.6%) created
and/or maintained their own web pages, many other practices were also followed.

The following table summarizes the responses
provided by the agency components:

Website Creation and Maintenance by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, the component created its own web pages and maintained
them.

204 (66.2%)

121 (68.8%)

43 (65.2%)

12 (66.7%)

21 (80.8%)

7 (31.8%)

(b) Yes and no. The component created the web pages, but another entity maintained them.

19 (6.2%)

8 (4.5%)

5 (7.6%)

2 (11.1%)

0 (0.0%)

4 (18.2%)

(c) Yes and no. Another entity created the web pages but the component maintained them.

10 (3.2%)

6 (3.4%)

2 (3.0%)

0 (0.0%)

0 (0.0%)

2 (9.1%)

(d) Yes and no. Some parts of the component created and maintained their own web pages, while
others adopted a different practice.

43 (14.0%)

24 (13.6%)

12 (18.2%)

3 (16.7%)

4 (15.4%)

0 (0.0%)

(e) No. An
independent contractor created and maintained the web pages.

18 (5.8%)

9 (5.1%)

3 (4.5%)

1 (5.6%)

1 (3.8%)

4 (18.2%)

(f) No. Another
federal agency created and maintained the web pages.

9 (2.9%)

4 (2.3%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

5 (22.7%)

(g) No. Another
entity created and maintained the web pages.

5 (1.6%)

4 (2.3%)

1 (1.5%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

Question
3 asked agency components to identify the most common types of content,
applications, or features used on their websites. This question permitted agency components to select any number of
available options. Thus, the total of
percentages within each column of the tables may exceed 100%. The agency components reported that Adobe
Acrobat (.pdf) files (95.8%) and video and audio
multimedia content (76.9%) were the most frequently used elements on their
websites. The agency components reported
that MySpace (7.8%) and Flickr (20.1%) were the most
infrequently used elements on their websites.

The following table provides the specific
responses by the agency components:

Website Elements by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Portable document files (.pdfs)

295 (95.8%)

165 (93.8%)

65 (98.5%)

18 (100.0%)

26 (100.0%)

21 (95.5%)

(b) Multimedia
content (video and audio)

237 (76.9%)

140 (79.5%)

51 (77.3%)

18 (100.0%)

18 (69.2%)

10 (45.5%)

(c) Flash
content

179 (58.1%)

113 (64.2%)

34 (51.5%)

15 (83.3%)

12 (46.2%)

5 (22.7%)

(d) Word
processing files

227 (73.7%)

135 (76.7%)

46 (69.7%)

15 (83.3%)

16 (61.5%)

15 (68.2%)

(e) Microsoft
PowerPoint files

206 (66.9%)

126 (71.6%)

44 (66.7%)

14 (77.8%)

13 (50.0%)

9 (40.9%)

(f) Data tables

207 (67.2%)

120 (68.2%)

41 (62.1%)

16 (88.9%)

19 (73.1%)

11 (50.0%)

(g) Spreadsheet
files

200 (64.9%)

117 (66.5%)

41 (62.1%)

17 (94.4%)

15 (57.7%)

10 (45.5%)

(h) JavaScript
or other Scripts

232 (75.3%)

140 (79.5%)

49 (74.2%)

18 (100.0%)

19 (73.1%)

6 (27.3%)

(i) Java applets

82 (26.6%)

57 (32.4%)

13 (19.7%)

6 (33.3%)

15 (57.7%)

1 (4.5%)

(j) Blogs (web
logs)

117 (38.0%)

69 (39.2%)

27 (19.7%)

11 (61.1%)

15 (57.7%)

2 (9.1%)

(k) Facebook

120 (39.0%)

79 (44.9%)

17 (25.8%)

11 (61.1%)

8 (30.8%)

1 (4.5%)

(l) MySpace

24 (7.8%)

19 (10.8%)

3 (4.5%)

2 (11.1%)

0 (0.0%)

0 (0.0%)

(m) Twitter

122 (39.6%)

72 (40.9%)

27 (40.9%)

10 (55.6%)

9 (34.6%)

4 (18.2%)

(n) YouTube

118 (38.3%)

73 (41.5%)

22 (33.3%)

11 (61.1%)

9 (34.6%)

3 (13.6%)

(o) Flickr

62 (20.1%)

43 (24.4%)

12 (18.2%)

4 (22.2%)

3 (11.5%)

0 (0.0%)

Question
4 asked whether agency components established a formal, written web
accessibility policy to ensure their websites comply with Section 508. Those agency components that did not
establish a formal, written policy were asked to skip the remaining questions
in this section regarding web accessibility policies. Overall, a majority of agency components
(70.4%) that created and maintained websites reported establishing web
accessibility policies. Small (50%) and
very small agency components (54.5%), however, reported a lower incidence of
establishing web accessibility policies.
Also, 32 agency components (10.4%) reported that they did not plan to
establish a web accessibility policy.

Specifically, the agency components provided
the following responses:

Section 508 Web Policy by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a formal, written web policy was established

119 (38.6%)

73 (41.5%)

20 (30.3%)

9 (50.0%)

8 (30.8%)

9 (40.9%)

(b) No, but a
timetable was established to do so

36 (11.7%)

12 (6.8%)

3 (4.5%)

4 (22.2%)

10 (38.5%)

7 (31.8%)

(c) No, and
there were no plans to do so

32 (10.4%)

17 (9.7%)

8 (12.1%)

1 (5.6%)

3 (11.5%)

3 (13.6%)

(d) Yes and no,
parts of our components have done this, while others have not

23 (7.5%)

11 (6.3%)

6 (9.1%)

4 (22.2%)

1 (3.8%)

1 (4.5%)

(e) Yes and no. While the components had not established a specific web policy, they followed
agency's web policy.

98 (31.8%)

63 (35.8%)

29 (43.9%)

0 (0.0%)

4 (15.4%)

2 (9.1%)

Question
5 asked whether each agency component’s web accessibility policy included
a process to ensure that employees that have responsibility for the content of
their website comply with the web accessibility policy. A total of 240 agency components that
established a web accessibility policy responded to this survey question. Overall, a majority of agency components (67.1%)
that established a web accessibility policy reported that those who have
responsibility for web content actually followed the web accessibility policy.

The agency components’ responses are
summarized in the table below:

Section 508 Web Policy by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, a process was established to ensure that those who are
responsible for web content followed the web policy

161 (67.1%)

104 (70.7%)

34 (61.8%)

6 (46.2%)

7 (53.8%)

10 (83.3%)

(b) No, while
parts of our components follow the web policy, a process was not established

64 (26.7%)

34 (23.1%)

18 (32.7%)

7 (53.8%)

4 (30.8%)

1 (8.3%)

(c) No, but a
timetable was established to do so

7 (2.9%)

4 (2.7%)

0 (0.0%)

0 (0.0%)

2 (15.4%)

1 (8.3%)

(d) No, and
there were no plans to do so

8 (3.3%)

5 (3.4%)

3 (5.5%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

Question
6 asked whether each agency component’s web accessibility policy
addressed the most common types of content, applications, or features used on
their websites. This question permitted
agency components to select any number of available options. Thus, the total of percentages within each
column of the tables may exceed 100%. A
majority of agency components reported that their web accessibility policies
addressed frequently used elements on their websites, such as Adobe Acrobat (.pdf) files (86.7%) and video and audio multimedia content
(70.8%).

The following table provides the agency components’
responses:

Section 508 Web Policy on Website
Elements by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Portable document files (.pdfs)

208 (86.7%)

124 (84.4%)

51 (92.7%)

11 (84.6%)

11 (84.6%)

11 (91.7%)

(b) Multimedia
content (video and audio)

170 (70.8%)

103 (70.1%)

43 (78.2%)

12 (92.3%)

8 (61.5%)

4 (33.3%)

(c) Flash
content

123 (51.2%)

79 (53.7%)

30 (54.5%)

9 (69.2%)

2 (15.4%)

3 (25.0%)

(d) Word
processing files

152 (63.3%)

96 (65.3%)

34 (61.8%)

9 (69.2%)

6 (46.2%)

7 (58.3%)

(e) Microsoft
PowerPoint files

131 (54.6%)

86 (58.5%)

28 (50.9%)

8 (61.5%)

4 (30.8%)

5 (41.7%)

(f) Data tables

148 (61.7%)

98 (66.7%)

31 (56.4%)

10 (76.9%)

4 (30.8%)

5 (41.7%)

(g) Spreadsheet
files

126 (52.5%)

78 (53.1%)

28 (50.9%)

9 (69.2%)

5 (38.5%)

6 (50.0%)

(h) JavaScript
or other Scripts

144 (60.0%)

91 (61.9%)

36 (65.5%)

9 (69.2%)

5 (38.5%)

3 (25.0%)

(i) Java applets

67 (27.9%)

47 (32.0%)

15 (27.3%)

3 (23.1%)

5 (38.5%)

1 (8.3%)

(j) Blogs (web
logs)

70 (29.2%)

48 (32.7%)

15 (27.3%)

4 (30.8%)

5 (38.5%)

1 (8.3%)

(k) Facebook

59 (24.6%)

40 (27.2%)

13 (23.6%)

3 (23.1%)

1 (7.7%)

1 (8.3%)

(l) MySpace

21 (8.8%)

16 (10.9%)

5 (9.1%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(m) Twitter

122 (50.8%)

37 (25.2%)

12 (21.8%)

2 (15.4%)

1 (7.7%)

0 (0.0%)

(n) YouTube

68 (28.3%)

46 (31.3%)

15 (27.3%)

4 (30.8%)

2 (15.4%)

1 (8.3%)

(o) Flickr

34 (14.2%)

24 (16.3%)

7 (12.7%)

1 (7.7%)

2 (15.4%)

0 (0.0%)

Question
7 asked whether each agency component’s web accessibility policy included
a process to routinely evaluate and remediate their websites for Section 508
compliance. Overall, a slight majority of agency
components (57.5%) reported performing routine automated and/or manual
evaluation and remediation on their websites.
Specifically, 27.9% of agency components performed both automated and
manual evaluation, while 23.8% of agency components performed only manual
evaluation, and 5.8% of agency components performed only automated
evaluation. Another 22.1% of agency
components reported performing evaluation and remediation only when notified of
accessibility problems. Surprisingly, 28
agency components (11.7%) reported that they had no plans to evaluate and
remediate their websites.

The agency components reported the following:

Section 508 Web Policy on Testing by
Number (Percent) of Components in Differently-Sized Agencies

(d) Yes, but we
evaluate and remediate only when notified of accessibility problems

53 (22.1%)

25 (17.0%)

17 (30.9%)

4 (30.8%)

2 (15.4%)

5 (41.7%)

(e) No, but a
timetable was established to do so

21 (8.8%)

13 (8.8%)

4 (7.3%)

1 (7.7%)

2 (15.4%)

1 (8.3%)

(f) No, and
there were no plans to do so

28 (11.7%)

16 (10.9%)

6 (10.9%)

2 (15.4%)

2 (15.4%)

2 (16.7%)

Question
8 asked whether agency components designated and advertised e-mail addresses on their website
to allow people with disabilities to inform the agency components of
accessibility problems encountered on their website. A total of 308 agency components responded to
this survey question. Overall, nearly
73.0% of agency components reported providing this e-mail address on their
websites.

The following table summarizes the responses
provided by the agency components:

Designated E-Mail Address by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes, an email address and instructions were available on the
website

195 (63.3%)

112 (63.6%)

38 (57.6%)

13 (72.2%)

14 (53.8%)

18 (81.8%)

(b) No, but a
telephone number and a TTY number were available on the website

20 (6.5%)

7 (4.0%)

5 (7.6%)

1 (5.6%)

5 (19.2%)

2 (9.1%)

(c) No, but a
timetable was established to do so

26 (8.4%)

17 (9.7%)

2 (3.0%)

1 (5.6%)

5 (19.2%)

1 (4.5%)

(d) No, and
there were no plans to do so

37 (12.0%)

22 (12.5%)

11 (16.7%)

1 (5.6%)

2 (7.7%)

1 (4.5%)

(e) Yes and no,
parts of our components have done this, while others have not

Agencies and their components were asked to
evaluate the accessibility of their Internet home pages, Intranet home pages,
web-based forms, and web-based applications.
A total of 318 agency components participated in this section. However, some agency components did not
complete parts of this section because they did not have an Internet home page,
Intranet home page, web-based form, or web-based application.

The following provides a brief summary of the
agency components’ responses:

Agency components reported very similar findings for their external
Internet and internal Intranet home pages.
More than eighty percent of agency components reported either
complying with the web requirements in the Section 508 EIT Accessibility
Standards or that the requirements were not applicable. For example, slightly more than eighty percent
of agency components reported the use of alternative text attribute or
other descriptive elements to represent non-text elements (images) on
their external Internet home pages, while five percent of agency
components reported that this requirement was not applicable. Also, slightly more than fifty percent
of agency components reported identifying row and column headers for data
tables on their external Internet home pages, while forty percent of
agency components reported that this requirement was not applicable. Agency components did, however, report
some difficulty in providing captioning and audio description for
multimedia content.

More than eighty-five percent of agency components reported either complying
with the requirements in the Section 508 EIT Accessibility Standards for
web-based forms or that the requirements were not applicable. For example, seventy-five percent agency
components reported the use of alternative text attribute or other
descriptive elements to represent non-text elements on their web-based
forms, while almost ten percent of agency components reported that this
requirement was not applicable.
Also, eighty percent of agency components reported that their forms
permitted users of assistive technology to access the information, field
elements, and functionality required for completion and submission of the
form, while seven percent of agency components reported that this
requirement was not applicable. Agency
components did, however, report some difficulty in providing keyboard
accessibility.

More than eighty percent of agency components reported either
complying with the requirements in the Section 508 EIT Accessibility
Standards for web-based applications or that the requirements were not
applicable. For example,
seventy-five percent of agency components reported the use of alternative
text attribute or other descriptive elements to represent non-text
elements on their web-based applications, while almost seven percent of
agency components reported that this requirement was not applicable. Also, slightly more than sixty percent
of agency components reported that their applications provided sufficient
information about user interface elements (such as check boxes, radio
buttons, menus, toolbars, dialog and popup windows and controls) to
assistive technology, while slightly more than twenty percent of agency
components reported that this requirement was not applicable. Agency components did, however, report
some difficulty in providing keyboard accessibility.

A total of 289 agency components that use external
Internet home pages responded to the following survey questions.

Question
1 asked agency components to provide the URLs for their external Internet
home pages.

Question
2 asked agency components to provide the best description of the purpose
of their external Internet web pages.
Overall, most agency components (74.4%) reported that their web pages
described the missions and activities of the component.

The following table provides the specific
responses by the agency components:

Purpose of Web Page by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Description of component's missions and activities

215 (74.4%)

126 (76.8%)

38 (62.3%)

13 (72.2%)

22 (84.6%)

16 (80.0%)

(b) Information
about programs and benefits

26 (9.0%)

12 (7.3%)

7 (11.5%)

2 (11.1%)

1 (3.8%)

4 (20.0%)

(c) Information
about products and services

25 (8.7%)

15 (9.1%)

6 (9.8%)

2 (11.1%)

2 (7.7%)

0 (0.0%)

(d) Publication
of resources

8 (2.8%)

3 (1.8%)

4 (6.6%)

0 (0.0%)

1 (3.8%)

0 (0.0%)

(e) Employment
postings

1 (0.3%)

1 (0.6%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(f) Other

14 (4.8%)

7 (4.3%)

6 (9.8%)

1 (5.6%)

0 (0.0%)

0 (0.0%)

Question
3 asked agency components about the use of “alt” (alternative text
attribute) or other descriptive elements to represent non-text elements in the
page. They are chiefly used to make
visual information accessible for people with visual impairments. Most agency components from all size
categories reported the use of the alternative text attribute or other
descriptive elements to represent non-text elements in the page. Overall, a majority of agency
components reported a high degree of success in meeting this requirement for
their surveyed web pages. Larger agency
components were more successful in meeting this requirement than smaller agency
components.

Specifically, the agency components provided
the following responses:

Text Equivalence by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

238 (82.4%)

134 (81.7%)

55 (90.2%)

17 (94.4%)

17 (65.4%)

15 (75.0%)

(b) No

37 (12.8%)

19 (11.6%)

4 (6.6%)

1 (5.6%)

9 (34.6%)

4 (20.0%)

(c) Not Applicable

14 (4.8%)

11 (6.7%)

2 (3.3%)

0 (0.0%)

0 (0.0%)

1 (5.0%)

Question
4 asked agency components whether audio description and text
captions provided were synchronized with their associated dynamic content. Synchronization allows the multimedia content
to be more accessible and readily understood by users with hearing and/or
visual impairments. Many agency
components (38.8%) reported that their web pages did not include multimedia
content. For those web pages with
multimedia content, a majority of agency components reported success with synchronized
captioning and descriptive text. Larger
agency components were more successful in meeting this requirement than smaller
agency components.

The agency components’ responses are
summarized in the table below:

Multimedia Content Accessibility
Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

134 (46.4%)

79 (48.2%)

31 (50.8%)

12 (66.7%)

7 (26.9%)

5 (25.0%)

(b) No

43 (14.9%)

25 (15.2%)

5 (8.2%)

0 (0.0%)

9 (34.6%)

4 (20.0%)

(c) Not Applicable

112 (38.8%)

60 (36.6%)

25 (41.0%)

6 (33.3%)

10 (38.5%)

11 (55.0%)

Question
5 asked agency components about the accessibility of their web pages
for users with varying degrees of color-blindness. Overall, a majority of agency components
reported that all information conveyed with color was also available without
color. Mid-size agency components were
the most successful in meeting this requirement.

The following table provides the agency components’
responses:

Appropriate Use of Color by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

194 (67.1%)

109 (66.5%)

42 (68.9%)

15 (83.3%)

15 (57.7%)

13 (65.0%)

(b) No

43 (14.9%)

26 (15.9%)

4 (6.6%)

0 (0.0%)

8 (30.8%)

5 (25.0%)

(c) Not Applicable

52 (18.0%)

29 (17.7%)

15 (24.6%)

3 (16.7%)

3 (11.5%)

2 (10.0%)

Question
6 focused on the use of Cascading Style Sheets (CSS) in web
pages. Agency components were asked
whether their web pages were readable if the corresponding style sheets were
deactivated, and whether the style sheets, if used, were designed so that they
did not interfere with custom style sheets set by the browser. Most agency components reported success in
meeting this requirement. Small agency
components were the least successful in meeting this requirement.

The agency components reported the following:

Style Sheet Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

242 (83.7%)

142 (86.6%)

49 (80.3%)

18 (100.0%)

16 (61.5%)

17 (85.0%)

(b) No

22 (7.6%)

14 (8.5%)

1 (1.6%)

0 (0.0%)

5 (19.2%)

2 (10.0%)

(c) Not Applicable

25 (8.7%)

8 (4.9%)

11 (18.0%)

0 (0.0%)

5 (19.2%)

1 (5.0%)

Question
7 asked agency components to provide information on the use of
server-side image maps and whether duplicate text links were provided for all
links within the image maps. A majority
of agency components (58.8%) from all agency size categories reported not using
image maps and thereby avoiding problems with this requirement. For those web pages with server-side image
maps, a majority of agency components reported having success with this
requirement.

The following table summarizes the responses
provided by the agency components:

Server-Side Image Map Accessibility by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

95 (32.9%)

55 (33.5%)

25 (41.0%)

6 (33.3%)

5 (19.2%)

4 (20.0%)

(b) No

24 (8.3%)

14 (8.5%)

1 (1.6%)

0 (0.0%)

7 (26.9%)

2 (10.0%)

(c) Not Applicable

170 (58.8%)

95 (57.9%)

35 (57.4%)

12 (66.7%)

14 (53.8%)

14 (70.0%)

Question
8 continues the image maps question by asking agency components
whether they provided client-side image maps instead of server-side image maps,
except where the regions cannot be defined with an available geometric shape. A majority of agency components (56.7%) from
all agency size categories reported not using image maps. For those web pages with image maps, a
majority of agency components reported success in providing client-side image
maps instead of server-side image maps.

The following table provides the specific
responses by the agency components:

Use of Client-Side Image Map by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

107 (37.0%)

61 (37.2%)

26 (42.6%)

6 (33.3%)

9 (34.6%)

5 (25.0%)

(b) No

18 (6.2%)

11 (6.7%)

1 (1.6%)

0 (0.0%)

4 (15.4%)

2 (10.0%)

(c) Not Applicable

164 (56.7%)

92 (56.1%)

34 (55.7%)

12 (66.7%)

13 (50.0%)

13 (65.0%)

Question
9 inquired about data tables in web pages. Agency components were asked if they
identified row and column headers (when such table headers existed) for data
tables in web pages. Many agency
components (40.5%) reported that their web pages did not include data
tables. For those web pages with data
tables, a majority of agency components reported success identifying row and
column headers for data tables. Small
agency components had more difficulty meeting this requirement.

Specifically, the agency components provided
the following responses:

Row and Column Header Identification by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

151 (52.2%)

84 (51.2%)

33 (54.1%)

10 (55.6%)

14 (53.8%)

10 (50.0%)

(b) No

21 (7.3%)

11 (6.7%)

5 (8.2%)

0 (0.0%)

5 (19.2%)

0 (0.0%)

(c) Not Applicable

117 (40.5%)

69 (42.1%)

23 (37.7%)

8 (44.4%)

7 (26.9%)

10 (50.0%)

Question
10 continues the data tables question by
asking agency components whether each cell in a data table was provided
identification of row and column headers (when such table headers existed). A majority of agency components (52.9%)
reported that their web pages did not include data tables. For those web pages with data tables, a
majority of agency components reported success associating data cells and
header cells. Small agency components
were the least successful in meeting this requirement.

The agency components’ responses are
summarized in the table below:

Data and Header Cell Association by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

113 (39.1%)

66 (40.2%)

26 (42.6%)

5 (27.8%)

8 (30.8%)

8 (40.0%)

(b) No

23 (8.0%)

12 (7.3%)

3 (4.9%)

0 (0.0%)

8 (30.8%)

0 (0.0%)

(c) Not Applicable

153 (52.9%)

86 (52.4%)

32 (52.5%)

13 (72.2%)

10 (38.5%)

12 (60.0%)

Question
11 asked agency components whether descriptive
titles were used for web pages with frames. A majority of agency components (64.4%)
reported that their web pages did not use frames. For those web pages with frames, a majority
of agency components reported success in meeting this requirement. Small agency components were the least
successful in meeting this requirement.

The following table provides the agency components’
responses:

Frame Accessibility by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

89 (30.8%)

55 (28.8%)

14 (21.1%)

6 (38.9%)

6 (20.0%)

8 (42.9%)

(b) No

14 (4.8%)

7 (8.5%)

3 (1.8%)

0 (5.6%)

4 (24.0%)

0 (0.0%)

(c) Not Applicable

186 (64.4%)

102 (62.2%)

44 (72.1%)

12 (66.7%)

16 (61.5%)

12 (60.0%)

Question
12 asked agency components whether content
(such as applets or plug-ins) on their web pages were designed to avoid causing
the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz. Overall, most agency components reported that
their web pages did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

205 (70.9%)

111 (67.7%)

48 (78.7%)

15 (83.3%)

17 (65.4%)

14 (70.0%)

(b) No

11 (3.8%)

6 (3.7%)

1 (1.6%)

0 (0.0%)

3 (11.5%)

1 (5.0%)

(c) Not Applicable

73 (25.3%)

47 (28.7%)

12 (19.7%)

3 (16.7%)

6 (23.1%)

5 (25.0%)

Question
13 asked whether agency components provided an
alternative text-only web page because their surveyed web pages contained barriers
to people with disabilities, and whether the alternative text-only web page
contained the same information and was updated as often as the inaccessible
surveyed web page. Many agency
components (47.8%) in all agency size categories reported that text-only
alternative pages were not needed because their web pages did not contain
barriers for people with disabilities. When
alternative text-only web pages were provided, a majority of agency components
reported success in providing up to date, equivalent information and
functionality.

The following table summarizes the responses
provided by the agency components:

Alternative Text-Only Page Availability
and Accessibility by Number (Percent) of Components in Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

105 (36.3%)

57 (34.8%)

24 (39.3%)

8 (44.4%)

6 (23.1%)

10 (50.0%)

(b) No

46 (15.9%)

26 (15.9%)

7 (11.5%)

1 (5.6%)

7 (26.9%)

5 (25.0%)

(c) Not Applicable

138 (47.8%)

81 (49.4%)

30 (49.2%)

9 (50.0%)

13 (50.0%)

5 (25.0%)

Question
14 asked agency components whether equivalent
text was made available for web pages using JavaScript or Macromedia Flash
scripts that affected content displayed to the user. Overall, a majority of agency components reported
that their web pages with scripting were accessible. Small agency components were the least
successful in meeting this requirement when scripting was used.

The following table provides the specific
responses by the agency components:

Java/Flash Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

187 (64.7%)

109 (66.5%)

39 (63.9%)

14 (77.8%)

13 (50.0%)

12 (60.0%)

(b) No

38 (13.1%)

21 (12.8%)

5 (8.2%)

1 (5.6%)

8 (30.8%)

3 (15.0%)

(c) Not Applicable

64 (22.1%)

34 (20.7%)

17 (27.9%)

3 (16.7%)

5 (19.2%)

5 (25.0%)

Question
15 asked agency components whether their web pages included a link
to the plug-in or other programmatic item required for accessing the content of
their web pages, and if that plug-in or other programmatic item itself was
accessible to people with disabilities. Many
agency components (37.7%) reported that their web pages did not use
programmatic elements. Overall, a
majority of agency components reported success in meeting this requirement.

Specifically, the agency components provided
the following responses:

Plug-In or Other Programmatic Object Accessibility
by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

153 (52.9%)

91 (55.5%)

30 (49.2%)

13 (72.2%)

8 (30.8%)

11 (55.0%)

(b) No

27 (9.3%)

15 (9.1%)

3 (4.9%)

0 (0.0%)

8 (30.8%)

1 (5.0%)

(c) Not Applicable

109 (37.7%)

58 (35.4%)

28 (45.9%)

5 (27.8%)

10 (38.5%)

8 (40.0%)

Question
16 asked agency components about their use of online electronic
forms. Specifically, agency components
were asked whether each form permitted users of assistive technology to access
the information, field elements, and functionality required for completion and
submission of the form, including all directions and cues. Many agency components (34.9%) reported that
their web pages did not use online electronic forms. Overall, a majority of agency components
reported that their forms were accessible.

The agency components’ responses are
summarized in the table below:

Electronic Form Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

163 (56.4%)

90 (54.9%)

39 (63.9%)

13 (72.2%)

9 (34.6%)

12 (60.0%)

(b) No

25 (8.7%)

13 (7.9%)

3 (4.9%)

1 (5.6%)

6 (23.1%)

2 (10.0%)

(c) Not Applicable

101 (34.9%)

61 (37.2%)

19 (31.1%)

4 (22.2%)

11 (42.3%)

6 (30.0%)

Question
17 asked agency components whether navigational links to other web
pages within the same website had special links that allowed screen readers to
skip over those navigational links. Overall,
a majority of agency components reported including skip navigational
links. Small agency components had more
difficulty meeting this requirement.

The following table provides the agency components’
responses:

Navigational Link Skipping by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

179 (61.9%)

104 (63.4%)

46 (75.4%)

14 (77.8%)

5 (19.2%)

10 (50.0%)

(b) No

46 (15.9%)

22 (13.4%)

4 (6.6%)

2 (11.1%)

14 (53.8%)

4 (20.0%)

(c) Not Applicable

64 (22.1%)

38 (23.2%)

11 (18.0%)

2 (11.1%)

7 (26.9%)

6 (30.0%)

Question
18 focused on web pages that imposed time limits on users. Specifically, agency components were asked if
users were alerted that they would be timed out and then given sufficient time
to indicate that more time was needed before actually being timed out. A majority of agency components (79.9%)
reported that time limits were not used. For those web pages that imposed time limits,
a majority of agency components reported success in meeting this requirement. Mid-size agency components were the most
successful in meeting this requirement.

The agency
components reported the following:

Time Limits by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

44 (15.2%)

29 (17.7%)

5 (8.2%)

7 (38.9%)

1 (3.8%)

2 (10.0%)

(b) No

14 (4.8%)

8 (4.9%)

2 (3.3%)

0 (0.0%)

3 (11.5%)

1 (5.0%)

(c) Not Applicable

231 (79.9%)

127 (77.4%)

54 (88.5%)

11 (61.1%)

22 (84.6%)

17 (85.0%)

Question
19 asked agency components whether programmatic elements on their web
pages provided keyboard accessibility.
Keyboard accessibility allows people with disabilities to access a
program’s controls and features from a keyboard instead of a mouse or other
pointing device. Many agency components
(39.4%) reported that their web pages did not use programmatic elements. Overall, a majority of agency components reported
success in meeting this requirement.

The following
table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

153 (52.9%)

90 (54.9%)

31 (50.8%)

11 (61.1%)

12 (46.2%)

9 (45.0%)

(b) No

22 (7.6%)

13 (7.9%)

4 (6.6%)

0 (0.0%)

5 (19.2%)

0 (0.0%)

(c) Not Applicable

114 (39.4%)

61 (37.2%)

26 (42.6%)

7 (38.9%)

9 (34.6%)

11 (55.0%)

Question
20 asked agency components whether programmatic elements on their
web pages provided a well-defined on-screen indication of the current focus
that moves with keyboard navigation. The
position on a screen where an action will take place is referred to as the
focus. Many agency components (34.6%)
reported that their web pages did not use programmatic elements. Overall, a majority of agency components reported
success in ensuring that focus was programmatically exposed so that assistive
technology can track focus.

The following
table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of
Components in Differently-Sized Agencies

Availability of User Interface
Information by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

190 (65.7%)

113 (68.9%)

42 (68.9%)

13 (72.2%)

10 (38.5%)

12 (60.0%)

(b) No

36 (12.5%)

17 (10.4%)

6 (9.8%)

1 (5.6%)

9 (34.6%)

3 (15.0%)

(c) Not Applicable

63 (21.8%)

34 (20.7%)

13 (21.3%)

4 (22.2%)

7 (26.9%)

5 (25.0%)

Question
22 asked whether agency components used text captioning for
multimedia content. Such accessibility
features are used to make multimedia features accessible to users with hearing
and/or visual impairments. Many agency
components (42.2%) reported that their surveyed web pages did not include
multimedia content. For those web pages
that used multimedia content, a majority of agency components reported success in
captioning multimedia content. Small and
very small agency components had more difficulty meeting this requirement.

The agency
components’ responses are summarized in the table below:

Captioning by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

115 (39.8%)

70 (42.7%)

27 (44.3%)

9 (50.0%)

6 (23.1%)

3 (15.0%)

(b) No

52 (18.0%)

26 (15.9%)

9 (14.8%)

3 (16.7%)

9 (34.6%)

5 (25.0%)

(c) Not Applicable

122 (42.2%)

68 (41.5%)

25 (41.0%)

6 (33.3%)

11 (42.3%)

12 (60.0%)

Question
23 asked whether agency components used descriptive narration for
multimedia content. Many agency
components (47.4%) reported that their surveyed web pages did not include
multimedia content. For those web pages
that used multimedia content, a majority of agency components reported success
in providing audio description for multimedia content. Small and very small agency components had more
difficulty meeting this requirement.

The following
table provides the agency components’ responses:

Audio Description by Number (Percent)
of Components in Differently-Sized Agencies

A total of 260 agency components that use internal
Intranet home pages responded to the following survey questions.

Question
1 asked agency components to provide the URLs for their internal Intranet
home pages.

Question
2 asked agency components to provide the best description of the purpose
of their internal Intranet web pages.
Overall, a majority of agency components reported that their web pages either
described the missions and activities of the component (35.0%) or provided
information about their programs and benefits (20.4%).

The following table provides the specific
responses by the agency components:

Purpose of Web Page by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Description of component's missions and activities

91 (35.0%)

62 (40.5%)

15 (26.3%)

8 (44.4%)

6 (24.0%)

0 (0.0%)

(b) Information
about programs and benefits

53 (20.4%)

21 (13.7%)

14 (24.6%)

4 (22.2%)

9 (36.0%)

5 (71.4%)

(c) Information
about products and services

30 (11.5%)

15 (9.8%)

9 (15.8%)

3 (16.7%)

3 (12.0%)

0 (0.0%)

(d) Publication
of resources

40 (15.4%)

24 (15.7%)

10 (17.5%)

1 (5.6%)

3 (12.0%)

2 (28.6%)

(e) Employment
postings

1 (0.4%)

1 (0.7%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(f) Other

45 (17.3%)

30 (19.6%)

9 (15.8%)

2 (11.1%)

4 (16.0%)

0 (0.0%)

Question
3 asked agency components about the use of “alt” (alternative text
attribute) or other descriptive elements to represent non-text elements in the
page. They are chiefly used make visual
information accessible for people with visual impairments. Most agency components from all size
categories reported the use of the alternative text attribute or other
descriptive elements to represent non-text elements in the page. Overall, a majority of agency
components reported a high degree of success in meeting this requirement for
their surveyed web pages. Small
agency components had more difficulty meeting this requirement.

Specifically, the agency components provided
the following responses:

Text Equivalence by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

196 (75.4%)

118 (77.1%)

47 (82.5%)

14 (77.8%)

12 (48.0%)

5 (71.4%)

(b) No

52 (20.0%)

29 (19.0%)

6 (10.5%)

3 (16.7%)

12 (48.0%)

2 (28.6%)

(c) Not Applicable

12 (4.6%)

6 (3.9%)

4 (7.0%)

1 (5.6%)

1 (4.0%)

0 (0.0%)

Question
4 asked agency components whether audio description and text
captions provided were synchronized with their associated dynamic content. Synchronization allows the multimedia content
to be more accessible and readily understood by users with hearing and/or
visual impairments. Many agency
components (47.7%) reported that their web pages did not include multimedia
content. For those web pages with
multimedia content, a majority of agency components reported having
synchronized captioning and descriptive text.
Small and very small agency components had more difficulty meeting this
requirement.

The agency components’ responses are
summarized in the table below:

Multimedia Content Accessibility
Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

91 (35.0%)

58 (37.9%)

21 (36.8%)

9 (50.0%)

3 (12.0%)

0 (0.0%)

(b) No

45 (17.3%)

28 (18.3%)

5 (8.8%)

1 (5.6%)

9 (36.0%)

2 (28.6%)

(c) Not Applicable

124 (47.7%)

67 (43.8%)

31 (54.4%)

8 (44.4%)

13 (52.0%)

5 (71.4%)

Question
5 asked agency components about the accessibility of their web pages
for users with varying degrees of color-blindness. Overall, a majority of agency components reported
that all information conveyed with color was also available without color. Mid-size agency components were the most
successful in meeting this requirement, and small agency components were the
least successful in meeting this requirement.

The following table provides the agency components’
responses:

Appropriate Use of Color by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

173 (66.5%)

100 (65.4%)

39 (68.4%)

15 (83.3%)

14 (56.0%)

5 (71.4%)

(b) No

32 (12.3%)

23 (15.0%)

1 (1.8%)

0 (0.0%)

7 (28.0%)

1 (14.3%)

(c) Not Applicable

55 (21.2%)

30 (19.6%)

17 (29.8%)

3 (16.7%)

4 (16.0%)

1 (14.3%)

Question
6 focused on the use of Cascading Style Sheets (CSS) in web
pages. Agency components were asked
whether their web pages were readable if the corresponding style sheets were
deactivated, and whether the style sheets, if used, were designed so that they
did not interfere with custom style sheets set by the browser. Most agency components reported success in
meeting this requirement. Small agency
components had more difficulty meeting this requirement.

The agency components reported the following:

Style Sheet Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

221 (85.0%)

129 (84.3%)

50 (87.7%)

18 (100.0%)

19 (76.0%)

5 (71.4%)

(b) No

26 (10.0%)

16 (10.5%)

4 (7.0%)

0 (0.0%)

5 (20.0%)

1 (14.3%)

(c) Not Applicable

13 (5.0%)

8 (5.2%)

3 (5.3%)

0 (0.0%)

1 (4.0%)

1 (14.3%)

Question
7 asked agency components to provide information on the use of
server-side image maps and whether duplicate text links were provided for all
links within the image maps. Overall, a
majority of agency components (60.8%) from all agency size categories reported not
using image maps and thereby avoiding problems with this requirement. For those web pages with server-side image
maps, a majority of agency components reported having success with this
requirement.

The following table summarizes the responses
provided by the agency components:

Server-Side Image Map Accessibility by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

86 (33.1%)

50 (32.7%)

21 (36.8%)

9 (50.0%)

4 (16.0%)

2 (28.6%)

(b) No

16 (6.2%)

10 (6.5%)

0 (0.0%)

0 (0.0%)

6 (24.0%)

0 (0.0%)

(c) Not Applicable

158 (60.8%)

93 (60.8%)

36 (63.2%)

9 (50.0%)

15 (60.0%)

5 (71.4%)

Question
8 continues the image maps question by asking agency components
whether they provided client-side image maps instead of server-side image maps,
except where the regions cannot be defined with an available geometric shape. A majority of agency components (63.5%) from
all agency size categories reported not using image maps. For those web pages with image maps, a
majority of agency components reported success in providing client-side image
maps instead of server-side image maps.

The following table provides the specific
responses by the agency components:

Use of Client-Side Image Map by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

82 (31.5%)

46 (30.1%)

21 (36.8%)

8 (44.4%)

5 (20.0%)

2 (28.6%)

(b) No

13 (5.0%)

9 (5.9%)

0 (0.0%)

0 (0.0%)

4 (16.0%)

0 (0.0%)

(c) Not Applicable

165 (63.5%)

98 (64.1%)

36 (63.2%)

10 (55.6%)

16 (64.0%)

5 (71.4%)

Question
9 inquired about data tables in web pages. Agency components were asked if they
identified row and column headers (when such table headers existed) for data
tables in web pages. Many agency
components (40.0%) reported that their web pages did not include data
tables. Overall, a majority of agency
components reported success identifying row and column headers for data tables. Small agency components had more difficulty meeting
this requirement.

Specifically, the agency components provided
the following responses:

Row and Column Header Identification by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

134 (51.5%)

83 (54.2%)

28 (49.1%)

11 (61.1%)

6 (24.0%)

6 (85.7%)

(b) No

22 (8.5%)

12 (7.8%)

3 (5.3%)

0 (0.0%)

7 (28.0%)

0 (0.0%)

(c) Not Applicable

104 (40.0%)

58 (37.9%)

26 (45.6%)

7 (38.9%)

12 (48.0%)

1 (14.3%)

Question
10 continues the data tables question by
asking agency components whether each cell in a data table was provided
identification of row and column headers (when such table headers existed). A majority of agency components (50.4%)
reported that their web pages did not include data tables. For those web pages with data tables, a
majority of agency components reported success associating data cells and
header cells. Small agency components
were the least successful in meeting this requirement.

The agency components’ responses are summarized
in the table below:

Data and Header Cell Association by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

105 (40.4%)

64 (41.8%)

22 (38.6%)

8 (44.4%)

7 (28.0%)

4 (57.1%)

(b) No

24 (9.2%)

13 (8.5%)

4 (7.0%)

0 (0.0%)

7 (28.0%)

0 (0.0%)

(c) Not Applicable

131 (50.4%)

76 (49.7%)

31 (54.4%)

10 (55.6%)

11 (44.0%)

3 (42.9%)

Question
11 asked agency components whether descriptive
titles were used for web pages with frames. A majority of agency components (64.6%)
reported that their web pages did not use frames. For those web pages with frames, a majority
of agency components reported success in meeting this requirement. Small agency components were the least
successful in meeting this requirement.

The following table provides the agency components’
responses:

Frame Accessibility by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

71 (27.3%)

44 (28.8%)

12 (21.1%)

7 (38.9%)

5 (20.0%)

3 (42.9%)

(b) No

21 (8.1%)

13 (8.5%)

1 (1.8%)

1 (5.6%)

6 (24.0%)

0 (0.0%)

(c) Not Applicable

168 (64.6%)

96 (62.7%)

44 (77.2%)

10 (55.6%)

14 (56.0%)

4 (57.1%)

Question
12 asked agency components whether content
(such as applets or plug-ins) on their web pages were designed to avoid causing
the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz. Overall, most agency components reported that
their web pages did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

165 (63.5%)

100 (65.4%)

34 (59.6%)

13 (72.2%)

13 (52.0%)

5 (71.4%)

(b) No

15 (5.8%)

8 (5.2%)

2 (3.5%)

0 (0.0%)

5 (20.0%)

0 (0.0%)

(c) Not Applicable

80 (30.8%)

45 (29.4%)

21 (36.8%)

5 (27.8%)

7 (28.0%)

2 (28.6%)

Question
13 asked whether agency components provided an
alternative text-only web page because their surveyed web pages contained barriers
to people with disabilities, and whether the alternative text-only web page
contained the same information and was updated as often as the inaccessible
surveyed web page. Many agency
components (44.6%) in all agency size categories reported that text-only
alternative pages were not needed because their web pages did not contain
barriers for people with disabilities.
When alternative text-only web pages were provided, a majority of agency
components reported success in providing up to date, equivalent information and
functionality.

The following table summarizes the responses
provided by the agency components:

Alternative Text-Only Page Availability
and Accessibility by Number (Percent) of Components in Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

98 (37.7%)

55 (35.9%)

25 (43.9%)

8 (44.4%)

7 (28.0%)

3 (42.9%)

(b) No

46 (17.7%)

28 (18.3%)

5 (8.8%)

2 (11.1%)

10 (40.0%)

1 (14.3%)

(c) Not Applicable

116 (44.6%)

70 (45.8%)

27 (47.4%)

8 (44.4%)

8 (32.0%)

3 (42.9%)

Question
14 asked agency components whether equivalent
text was made available for web pages using JavaScript or Macromedia Flash
scripts that affected content displayed to the user. Overall, a majority of agency components reported
that their web pages with scripting were accessible. Small agency components were the least
successful in meeting this requirement when scripting was used.

The following table provides the specific
responses by the agency components:

Java/Flash Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

147 (56.5%)

90 (58.8%)

31 (54.4%)

14 (77.8%)

9 (36.0%)

3 (42.9%)

(b) No

42 (16.2%)

24 (15.7%)

7 (12.3%)

1 (5.6%)

9 (36.0%)

1 (14.3%)

(c) Not Applicable

71 (27.3%)

39 (25.5%)

19 (33.3%)

3 (16.7%)

7 (28.0%)

3 (42.9%)

Question
15 asked agency components whether their web pages included a link
to the plug-in or other programmatic item required for accessing the content of
their web pages, and if that plug-in or other programmatic item itself was
accessible to people with disabilities. Many
agency components (47.7%) reported that their web pages did not use
programmatic elements. For those web
pages with programmatic elements, a majority of agency components reported
success in meeting this requirement.

Specifically, the agency components provided
the following responses:

Plug-In or Other Programmatic Object Accessibility
by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

107 (41.2%)

63 (41.2%)

21 (36.8%)

10 (55.6%)

8 (32.0%)

5 (71.4%)

(b) No

29 (11.2%)

17 (11.1%)

4 (7.0%)

1 (5.6%)

7 (28.0%)

0 (0.0%)

(c) Not Applicable

124 (47.7%)

73 (47.7%)

32 (56.1%)

7 (38.9%)

10 (40.0%)

2 (28.6%)

Question
16 asked agency components about their use of online electronic
forms. Specifically, agency components
were asked whether each form permitted users of assistive technology to access
the information, field elements, and functionality required for completion and
submission of the form, including all directions and cues. Many agency components (30.0%) reported that
their web pages did not use online electronic forms. Overall, a majority of agency components reported
that their forms were accessible.

The agency components’ responses are
summarized in the table below:

Electronic Form Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

148 (56.9%)

91 (59.5%)

29 (50.9%)

14 (77.8%)

10 (40.0%)

4 (57.1%)

(b) No

34 (13.1%)

22 (14.4%)

3 (5.3%)

0 (0.0%)

8 (32.0%)

1 (14.3%)

(c) Not Applicable

78 (30.0%)

40 (26.1%)

25 (43.9%)

4 (22.2%)

7 (28.0%)

2 (28.6%)

Question
17 asked agency components whether navigational links to other web
pages within the same website had special links that allowed screen readers to
skip over those navigational links.
Overall, a majority of agency components reported including skip
navigational links. Small agency
components had more difficulty meeting this requirement.

The following table provides the agency components’
responses:

Navigational Link Skipping by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

145 (55.8%)

86 (56.2%)

34 (59.6%)

12 (66.7%)

10 (40.0%)

3 (42.9%)

(b) No

51 (19.6%)

30 (19.6%)

8 (14.0%)

3 (16.7%)

9 (36.0%)

1 (14.3%)

(c) Not Applicable

64 (24.6%)

37 (24.2%)

15 (26.3%)

3 (16.7%)

6 (24.0%)

3 (42.9%)

Question
18 focused on web pages that imposed time limits on users. Specifically, agency components were asked if
users were alerted that they would be timed out and then given sufficient time
to indicate that more time was needed before actually being timed out. Most agency components (78.8%) reported that
time limits were not used. For those web
pages that imposed time limits, a majority of agency components reported
success in meeting this requirement.
Mid-size agency components were the most successful in meeting this
requirement.

The agency
components reported the following:

Time Limits by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

43 (16.5%)

29 (19.0%)

7 (12.3%)

6 (33.3%)

0 (0.0%)

1 (14.3%)

(b) No

12 (4.6%)

8 (5.2%)

2 (3.5%)

0 (0.0%)

2 (8.0%)

0 (0.0%)

(c) Not Applicable

205 (78.8%)

116 (75.8%)

48 (84.2%)

12 (66.7%)

23 (92.0%)

6 (85.7%)

Question
19 asked agency components whether programmatic elements on their
web pages provided keyboard accessibility.
Keyboard accessibility allows people with disabilities to access a
program’s controls and features from a keyboard instead of a mouse or other
pointing device. Many agency components
(38.1%) reported that their web pages did not use programmatic elements. Overall, a majority of agency components
reported success in meeting this requirement.

The following
table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

131 (50.4%)

79 (51.6%)

25 (43.9%)

13 (72.2%)

10 (40.0%)

4 (57.1%)

(b) No

30 (11.5%)

18 (11.8%)

4 (7.0%)

1 (5.6%)

6 (24.0%)

1 (14.3%)

(c) Not Applicable

99 (38.1%)

56 (36.6%)

28 (49.1%)

4 (22.2%)

9 (36.0%)

2 (28.6%)

Question
20 asked agency components whether programmatic elements on their
web pages provided a well-defined on-screen indication of the current focus
that moves with keyboard navigation. The
position on a screen where an action will take place is referred to as the focus. Many agency components (34.6%) reported that
their web pages did not use programmatic elements. For those web pages with programmatic
elements, a majority of agency components reported success in ensuring that
focus was programmatically exposed so that assistive technology can track
focus.

The following
table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of
Components in Differently-Sized Agencies

Availability of User Interface
Information by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

157 (60.4%)

96 (62.7%)

38 (66.7%)

10 (55.6%)

9 (36.0%)

4 (57.1%)

(b) No

37 (14.2%)

22 (14.4%)

4 (7.0%)

2 (11.1%)

8 (32.0%)

1 (14.3%)

(c) Not Applicable

66 (25.4%)

35 (22.9%)

15 (26.3%)

6 (33.3%)

8 (32.0%)

2 (28.6%)

Question
22 asked whether agency components used text captioning for
multimedia content. Such accessibility
features are used to make multimedia features accessible to users with hearing
and/or visual impairments. Many agency
components (45.0%) reported that their surveyed web pages did not include
multimedia content. For those web pages
that used multimedia content, a majority of agency components reported success
in captioning multimedia content. Small agency
components had more difficulty meeting this requirement.

The agency
components’ responses are summarized in the table below:

Captioning by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

91 (35.0%)

56 (36.6%)

21 (36.8%)

10 (55.6%)

3 (12.0%)

1 (14.3%)

(b) No

52 (20.0%)

33 (21.6%)

7 (12.3%)

2 (11.1%)

9 (36.0%)

1 (14.3%)

(c) Not Applicable

117 (45.0%)

64 (41.8%)

29 (50.9%)

6 (33.3%)

13 (52.0%)

5 (71.4%)

Question
23 asked whether agency components used descriptive narration for
multimedia content. A majority of agency
components (52.7%) reported that their surveyed web pages did not include
multimedia content. For those web pages
that used multimedia content, a majority of agency components reported success
in providing audio description for multimedia content. Small agency components had more difficulty meeting
this requirement.

The following
table provides the agency components’ responses:

Audio Description by Number (Percent)
of Components in Differently-Sized Agencies

A total of 235 agency components that used
web-based forms responded to the following survey questions.

Question
1 asked agency components to provide the URLs for their web-based forms.

Question
2 asked agency components to provide the best description of the purpose
of their web-based form. Overall, agency
components (30.6%) reported that the most common purpose for a web-based form
was for providing feedback to the component.

The following table provides the specific
responses by the agency components:

Purpose of Web-Based Form by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Applying for programs and benefits

27 (11.5%)

15 (11.0%)

1 (2.1%)

2 (11.8%)

4 (18.2%)

5 (38.5%)

(b) Ordering
products and services

32 (13.6%)

23 (16.9%)

3 (6.4%)

2 (11.8%)

4 (18.2%)

0 (0.0%)

(c) Feedback

72 (30.6%)

42 (30.9%)

22 (46.8%)

1 (5.9%)

4 (18.2%)

3 (23.1%)

(d) Contact
information search

15 (6.4%)

7 (5.1%)

4 (8.5%)

4 (23.5%)

0 (0.0%)

0 (0.0%)

(e) Publication
resource search

13 (5.5%)

9 (6.6%)

1 (2.1%)

1 (5.9%)

1 (4.5%)

1 (7.7%)

(f) Filing a
complaint

13 (5.5%)

3 (2.2%)

4 (8.5%)

3 (17.6%)

2 (9.1%)

1 (7.7%)

(g) Employment
search

1 (0.4%)

1 (0.7%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(h) Other

62 (26.4%)

36 (26.5%)

12 (25.5%)

4 (23.5%)

7 (31.8%)

3 (23.1%)

Question
3 asked agency components about the use of “alt” (alternative text
attribute) or other descriptive elements to represent non-text elements in the
web-based form. They are chiefly used to
make visual information accessible for people with visual impairments. Most agency components from all size
categories reported the use of the alternative text attribute or other
descriptive elements to represent non-text elements. Overall, a majority of agency
components reported a high degree of success in meeting this requirement for
their surveyed forms.

Specifically, the agency components provided
the following responses:

Text Equivalence by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

177 (75.3%)

107 (78.7%)

35 (74.5%)

13 (76.5%)

13 (59.1%)

9 (69.2%)

(b) No

36 (15.3%)

19 (14.0%)

7 (14.9%)

2 (11.8%)

6 (27.3%)

2 (15.4%)

(c) Not Applicable

22 (9.4%)

10 (7.4%)

5 (10.6%)

2 (11.8%)

3 (13.6%)

2 (15.4%)

Question
4 asked agency components whether audio description and text
captions provided were synchronized with their associated dynamic content. Synchronization allows the multimedia content
to be more accessible and readily understood by users with hearing and/or
visual impairments. Most agency
components (77.9%) reported that their web-based forms did not include
multimedia content.

The agency components’ responses are
summarized in the table below:

Multimedia Content Accessibility
Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

34 (14.5%)

21 (15.4%)

4 (8.5%)

5 (29.4%)

2 (9.1%)

2 (15.4%)

(b) No

18 (7.7%)

15 (11.0%)

1 (2.1%)

0 (0.0%)

1 (4.5%)

1 (7.7%)

(c) Not Applicable

183 (77.9%)

100 (73.5%)

42 (89.4%)

12 (70.6%)

19 (86.4%)

10 (76.9%)

Question
5 asked agency components about the accessibility of their
web-based forms for users with varying degrees of color-blindness. Overall, a majority of agency components reported
that all information conveyed with color was also available without color.

The following table provides the agency components’
responses:

Appropriate Use of Color by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

146 (62.1%)

84 (61.8%)

30 (63.8%)

12 (70.6%)

13 (59.1%)

7 (53.8%)

(b) No

19 (8.1%)

15 (11.0%)

1 (2.1%)

0 (0.0%)

2 (9.1%)

1 (7.7%)

(c) Not Applicable

70 (29.8%)

37 (27.2%)

16 (34.0%)

5 (29.4%)

7 (31.8%)

5 (38.5%)

Question
6 focused on the use of Cascading Style Sheets (CSS). Agency components were asked whether their
forms were readable if the corresponding style sheets were deactivated, and whether
the style sheets, if used, were designed so that they did not interfere with
custom style sheets set by the browser.
Overall, most agency components reported success meeting this
requirement.

The agency components reported the following:

Style Sheet Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

188 (80.0%)

109 (80.1%)

39 (83.0%)

16 (94.1%)

17 (77.3%)

7 (53.8%)

(b) No

16 (6.8%)

13 (9.6%)

0 (0.0%)

0 (0.0%)

1 (4.5%)

2 (15.4%)

(c) Not Applicable

31 (13.2%)

14 (10.3%)

8 (17.0%)

1 (5.9%)

4 (18.2%)

4 (30.8%)

Question
7 asked agency components to provide information on the use of
server-side image maps and whether duplicate text links were provided for all
links within the image maps. A majority
of agency components (71.5%) from all agency size categories reported not using
image maps and thereby avoiding problems with this requirement. For those web-based forms with server-side
image maps, a majority of agency components reported having success with this
requirement.

The following table summarizes the responses
provided by the agency components:

Server-Side Image Map Accessibility by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

55 (23.4%)

30 (22.1%)

12 (25.5%)

5 (29.4%)

3 (13.6%)

5 (38.5%)

(b) No

12 (5.1%)

8 (5.9%)

0 (0.0%)

0 (0.0%)

2 (9.1%)

2 (15.4%)

(c) Not Applicable

168 (71.5%)

98 (72.1%)

35 (74.5%)

12 (70.6%)

17 (77.3%)

6 (46.2%)

Question
8 continues the image maps question by asking agency components
whether they provided client-side image maps instead of server-side image maps,
except where the regions cannot be defined with an available geometric shape. A majority of agency components (75.3%) from
all agency size categories reported not using image maps. For those web-based forms with image maps, a
majority of agency components reported success in providing client-side image
maps instead of server-side image maps.

The following table provides the specific
responses by the agency components:

Use of Client-Side Image Map by Number
(Percent) of Components in Differently-Sized Agencies

Row and Column Header Identification by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

86 (36.6%)

54 (39.7%)

12 (25.5%)

8 (47.1%)

6 (27.3%)

6 (46.2%)

(b) No

17 (7.2%)

5 (3.7%)

5 (10.6%)

0 (0.0%)

6 (27.3%)

1 (7.7%)

(c) Not Applicable

132 (56.2%)

77 (56.6%)

30 (63.8%)

9 (52.9%)

10 (45.5%)

6 (46.2%)

Question
10 continues the data tables question by
asking agency components whether each cell in a data table was provided
identification of row and column headers (when such table headers existed). A majority of agency components (60.4%)
reported that their web-based forms did not include data tables. For those web-based forms with data tables, a
majority of agency components reported success associating data cells and
header cells. Small agency components
were the least successful in meeting this requirement.

The agency components’ responses are
summarized in the table below:

Data and Header Cell Association by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

80 (34.0%)

49 (36.0%)

15 (31.9%)

6 (35.3%)

5 (22.7%)

5 (38.5%)

(b) No

13 (5.5%)

5 (3.7%)

2 (4.3%)

0 (0.0%)

5 (22.7%)

1 (7.7%)

(c) Not Applicable

142 (60.4%)

82 (60.3%)

30 (63.8%)

11 (64.7%)

12 (54.5%)

7 (53.8%)

Question
11 asked agency components whether descriptive
titles were used for web-based forms with frames. A majority of agency components (74.5%)
reported that their web-based forms did not use frames. For those web-based forms with frames, a
majority of agency components reported success in meeting this requirement.

The following table provides the agency components’
responses:

Frame Accessibility by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

54 (23.0%)

29 (21.3%)

11 (23.4%)

5 (29.4%)

3 (13.6%)

6 (46.2%)

(b) No

6 (2.6%)

3 (2.2%)

1 (2.1%)

0 (0.0%)

1 (4.5%)

1 (7.7%)

(c) Not Applicable

175 (74.5%)

104 (76.5%)

35 (74.5%)

12 (70.6%)

18 (81.8%)

6 (46.2%)

Question
12 asked agency components whether content on
their web-based forms were designed to avoid causing the screen to flicker with
a frequency greater than 2 Hz and lower than 55 Hz. Overall, a majority of agency components
reported that their web-based forms did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

147 (62.6%)

83 (61.0%)

31 (66.0%)

12 (70.6%)

11 (50.0%)

10 (76.9%)

(b) No

6 (2.6%)

3 (2.2%)

0 (0.0%)

0 (0.0%)

2 (9.1%)

1 (7.7%)

(c) Not Applicable

82 (34.9%)

50 (36.8%)

16 (34.0%)

5 (29.4%)

9 (40.9%)

2 (15.4%)

Question
13 asked whether agency components provided a
text-only alternative because their surveyed web-based forms contained barriers
to people with disabilities, and whether the text-only alternative contained
the same information and was updated as often as the inaccessible surveyed
web-based form. A majority of agency
components (55.7%) in all agency size categories reported that text-only
alternatives were not needed because their web-based forms did not contain
barriers for people with disabilities.
When alternative text-only forms were provided, a majority of agency
components reported success in providing up to date, equivalent information and
functionality.

The following table summarizes the responses
provided by the agency components:

Alternative Text-Only Page Availability and Accessibility by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

74 (31.5%)

37 (27.2%)

17 (36.2%)

8 (47.1%)

6 (27.3%)

6 (46.2%)

(b) No

30 (12.8%)

18 (13.2%)

4 (8.5%)

1 (5.9%)

5 (22.7%)

2 (15.4%)

(c) Not Applicable

131 (55.7%)

81 (59.6%)

26 (55.3%)

8 (47.1%)

11 (50.0%)

5 (38.5%)

Question
14 asked agency components whether equivalent
text was made available for web-based forms using JavaScript or Macromedia
Flash scripts that affected content displayed to the user. Many agency components (36.2%) reported that
their web-based forms did not use scripts.
Overall, a majority of agency components reported that their web-based
forms were accessible.

The following table provides the specific
responses by the agency components:

Java/Flash Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

125 (53.2%)

72 (52.9%)

24 (51.1%)

11 (64.7%)

9 (40.9%)

9 (69.2%)

(b) No

25 (10.6%)

14 (10.3%)

4 (8.5%)

2 (11.8%)

4 (18.2%)

1 (7.7%)

(c) Not Applicable

85 (36.2%)

50 (36.8%)

19 (40.4%)

4 (23.5%)

9 (40.9%)

3 (23.1%)

Question
15 asked agency components whether they included a link to the plug-in
or other programmatic item required for accessing the content of their web-based
form, and if that plug-in or other programmatic item itself was accessible to
people with disabilities. A majority of
agency components (60.9%) reported that their web-based forms did not require a
plug-in or other programmatic item. For
those web-based forms with programmatic elements, a majority of agency
components reported success in meeting this requirement.

Specifically, the agency components provided
the following responses:

Plug-In or Other Programmatic Object Accessibility
by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

74 (31.5%)

48 (35.3%)

9 (19.1%)

8 (47.1%)

4 (18.2%)

5 (38.5%)

(b) No

18 (7.7%)

12 (8.8%)

3 (6.4%)

0 (0.0%)

1 (4.5%)

2 (15.4%)

(c) Not Applicable

143 (60.9%)

76 (55.9%)

35 (74.5%)

9 (52.9%)

17 (77.3%)

6 (46.2%)

Question
16 asked agency components about their use of online electronic
forms. Specifically, agency components
were asked whether each form permitted users of assistive technology to access
the information, field elements, and functionality required for completion and
submission of the form, including all directions and cues. Overall, most agency components reported that
their forms were accessible. Small
agency components had more difficulty meeting this requirement.

The agency components’ responses are
summarized in the table below:

Electronic Form Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

188 (80.0%)

109 (80.1%)

40 (85.1%)

15 (88.2%)

15 (68.2%)

9 (69.2%)

(b) No

30 (12.8%)

17 (12.5%)

5 (10.6%)

1 (5.9%)

6 (27.3%)

1 (7.7%)

(c) Not Applicable

17 (7.2%)

10 (7.4%)

2 (4.3%)

1 (5.9%)

1 (4.5%)

3 (23.1%)

Question
17 asked agency components whether web-based forms included special
links that allowed screen readers to skip over navigational links. Overall, a majority of agency components reported
including skip navigational links. Small
agency components had more difficulty meeting this requirement.

The following table provides the agency components’
responses:

Navigational Link Skipping by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

134 (57.0%)

73 (53.7%)

34 (72.3%)

13 (76.5%)

8 (36.4%)

6 (46.2%)

(b) No

32 (13.6%)

20 (14.7%)

1 (2.1%)

2 (11.8%)

7 (31.8%)

2 (15.4%)

(c) Not Applicable

69 (29.4%)

43 (31.6%)

12 (25.5%)

2 (11.8%)

7 (31.8%)

5 (38.5%)

Question
18 focused on web-based forms that imposed time limits on users. Specifically, agency components were asked if
users were alerted that they would be timed out and then given sufficient time
to indicate that more time was needed before actually being timed out. Most agency components (77.4%) reported that
time limits were not used. For those
web-based forms that imposed time limits, a majority of agency components
reported success in meeting this requirement.

The agency
components reported the following:

Time Limits by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

41 (17.4%)

25 (18.4%)

4 (8.5%)

7 (41.2%)

3 (13.6%)

2 (15.4%)

(b) No

12 (5.1%)

8 (5.9%)

1 (2.1%)

0 (0.0%)

2 (9.1%)

1 (7.7%)

(c) Not Applicable

182 (77.4%)

103 (75.7%)

42 (89.4%)

10 (58.8%)

17 (77.3%)

10 (76.9%)

Question
19 asked agency components whether their web-based forms provided
keyboard accessibility. Keyboard
accessibility allows people with disabilities to access a program’s controls
and features from a keyboard instead of a mouse or other pointing device. Overall, a majority of agency components
reported success in meeting this requirement.

The following
table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

152 (64.7%)

92 (67.6%)

26 (55.3%)

12 (70.6%)

14 (63.6%)

8 (61.5%)

(b) No

18 (7.7%)

9 (6.6%)

2 (4.3%)

1 (5.9%)

4 (18.2%)

2 (15.4%)

(c) Not Applicable

65 (27.7%)

35 (25.7%)

19 (40.4%)

4 (23.5%)

4 (18.2%)

3 (23.1%)

Question
20 asked agency components whether their web-based forms provided a
well-defined on-screen indication of the current focus that moves with keyboard
navigation. The position on a screen
where an action will take place is referred to as the focus. Overall, a majority of agency components reported
success in ensuring that focus was programmatically exposed so that assistive
technology can track focus.

The following
table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of
Components in Differently-Sized Agencies

Availability of User Interface
Information by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

134 (57.0%)

79 (58.1%)

29 (61.7%)

11 (64.7%)

8 (36.4%)

7 (53.8%)

(b) No

27 (11.5%)

19 (14.0%)

2 (4.3%)

1 (5.9%)

3 (13.6%)

2 (15.4%)

(c) Not Applicable

74 (31.5%)

38 (27.9%)

16 (34.0%)

5 (29.4%)

11 (50.0%)

4 (30.8%)

Question
22 asked whether agency components used text captioning for
multimedia content. Such accessibility
features are used to make multimedia features accessible to users with hearing
and/or visual impairments. A majority of
agency components (77.0%) reported that their web-based forms did not include
multimedia content. The agency components’ responses are summarized in
the table below:

Captioning by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

37 (15.7%)

22 (16.2%)

5 (10.6%)

5 (29.4%)

4 (18.2%)

1 (7.7%)

(b) No

17 (7.2%)

13 (9.6%)

0 (0.0%)

1 (5.9%)

2 (9.1%)

1 (7.7%)

(c) Not Applicable

181 (77.0%)

101 (74.3%)

42 (89.4%)

11 (64.7%)

16 (72.7%)

11 (84.6%)

Question
23 asked whether agency components used descriptive narration for
multimedia content. A majority of agency
components (78.3%) reported that their web-based forms did not include
multimedia content.

The following
table provides the agency components’ responses:

Audio Description by Number (Percent)
of Components in Differently-Sized Agencies

A total of 223 agency components that used
web-based applications responded to the following survey questions.

Question
1 asked agency components to provide the URLs for their web-based
applications.

Question
2 asked agency components to provide the best description of the purpose
of their web-based applications. Many agency
components selected record keeping and tracking (17.9%), employment (13.0%),
and ordering products and services (10.8%) as the purpose of their web-based
applications.

The following table provides the specific
responses by the agency components:

Purpose of Web-Based Applications by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Applying for programs and benefits

21 (9.4%)

9 (6.9%)

5 (10.9%)

2 (11.8%)

3 (14.3%)

2 (25.0%)

(b) Ordering
products and services

24 (10.8%)

17 (13.0%)

4 (8.7%)

2 (11.8%)

1 (4.8%)

0 (0.0%)

(c) Training and
learning

23 (10.3%)

16 (12.2%)

4 (8.7%)

0 (0.0%)

1 (4.8%)

2 (25.0%)

(d) Travel
reservation

1 (0.4%)

0 (0.0%)

1 (2.2%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(e) Time and
attendance

17 (7.6%)

12 (9.2%)

2 (4.3%)

1 (5.9%)

2 (9.5%)

0 (0.0%)

(f) Record
keeping and tracking

40 (17.9%)

21 (16.0%)

10 (21.7%)

3 (17.6%)

3 (14.3%)

3 (37.5%)

(g) Survey

3 (1.3%)

1 (0.8%)

2 (4.3%)

0 (0.0%)

0 (0.0%)

0 (0.0%)

(h) Employment

29 (13.0%)

23 (17.6%)

5 (10.9%)

1 (5.9%)

0 (0.0%)

0 (0.0%)

(i) Other

65 (29.1%)

32 (24.4%)

13 (28.3%)

8 (47.1%)

11 (52.4%)

1 (12.5%)

Question
3 asked agency components about the use of “alt” (alternative text
attribute) or other descriptive elements to represent non-text elements in the
web-based application. They are chiefly
used to make visual information accessible for people with visual
impairments. Most agency
components from all size categories reported the use of the alternative text
attribute or other descriptive elements to represent non-text elements. Overall, a majority of agency
components reported a high degree of success in meeting this requirement for
their web-based applications. Small
agency components had more difficulty meeting this
requirement.

Specifically, the agency components provided
the following responses:

Text Equivalence by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

167 (74.9%)

102 (77.9%)

36 (78.3%)

13 (76.5%)

10 (47.6%)

6 (75.0%)

(b) No

41 (18.4%)

24 (18.3%)

6 (13.0%)

1 (5.9%)

9 (42.9%)

1 (12.5%)

(c) Not Applicable

15 (6.7%)

5 (3.8%)

4 (8.7%)

3 (17.6%)

2 (9.5%)

1 (12.5%)

Question
4 asked agency components whether audio description and text
captions provided were synchronized with their associated dynamic content. Synchronization allows the multimedia content
to be even more accessible and readily understood by users with hearing and/or
visual impairments. Most agency
components (69.1%) reported that their web-based applications did not include
multimedia content.

The agency components’ responses are
summarized in the table below:

Multimedia Content Accessibility
Synchronization by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

45 (20.2%)

21 (16.0%)

14 (30.4%)

5 (29.4%)

2 (9.5%)

3 (37.5%)

(b) No

24 (10.8%)

22 (16.8%)

0 (0.0%)

1 (5.9%)

1 (4.8%)

0 (0.0%)

(c) Not Applicable

154 (69.1%)

88 (67.2%)

32 (69.6%)

11 (64.7%)

18 (85.7%)

5 (62.5%)

Question
5 asked agency components about the accessibility of their
web-based applications for users with varying degrees of color-blindness. Overall, a majority of agency components reported
that all information conveyed with color was also available without color. Mid-size agency components were the most
successful in meeting this requirement.

The following table provides the agency components’
responses:

Appropriate Use of Color by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

150 (67.3%)

84 (64.1%)

32 (69.6%)

14 (82.4%)

14 (66.7%)

6 (75.0%)

(b) No

21 (9.4%)

14 (10.7%)

5 (10.9%)

1 (5.9%)

1 (4.8%)

0 (0.0%)

(c) Not Applicable

52 (23.3%)

33 (25.2%)

9 (19.6%)

2 (11.8%)

6 (28.6%)

2 (25.0%)

Question
6 focused on the use of Cascading Style Sheets (CSS). Agency components were asked whether their
web-based applications were viewable if the corresponding style sheets were
deactivated, and whether the style sheets, if used, were designed so that they
did not interfere with custom style sheets set by the browser. Overall, a majority of agency components reported
success in meeting this requirement.
The agency components reported the following:

Style Sheet Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

165 (74.0%)

99 (75.6%)

34 (73.9%)

14 (82.4%)

13 (61.9%)

5 (62.5%)

(b) No

24 (10.8%)

19 (14.5%)

2 (4.3%)

1 (5.9%)

2 (9.5%)

0 (0.0%)

(c) Not Applicable

34 (15.2%)

13 (9.9%)

10 (21.7%)

2 (11.8%)

6 (28.6%)

3 (37.5%)

Question
7 asked agency components to provide information on the use of
server-side image maps and whether duplicate text links were provided for all
links within the image maps. A majority
of agency components (69.5%) from all agency size categories reported not using
image maps and thereby avoiding problems with this requirement. For those web-based applications with
server-side image maps, a majority of agency components reported having success
with this requirement.

The following table summarizes the responses
provided by the agency components:

Server-Side Image Map Accessibility by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

56 (25.1%)

29 (22.1%)

17 (37.0%)

4 (23.5%)

4 (19.0%)

2 (25.0%)

(b) No

12 (5.4%)

8 (6.1%)

2 (4.3%)

0 (0.0%)

2 (9.5%)

0 (0.0%)

(c) Not Applicable

155 (69.5%)

94 (71.8%)

27 (58.7%)

13 (76.5%)

15 (71.4%)

6 (75.0%)

Question
8 continues the image maps question by asking agency components
whether they provided client-side image maps instead of server-side image maps,
except where the regions cannot be defined with an available geometric shape. A majority of agency components (70.4%) from
all agency size categories reported not using image maps. For those web-based applications with image
maps, a majority of agency components reported success in providing client-side
image maps instead of server-side image maps.

The following table provides the specific
responses by the agency components:

Use of Client-Side Image Map by Number
(Percent) of Components in Differently-Sized Agencies

Row and Column Header Identification by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

137 (61.4%)

83 (63.4%)

27 (58.7%)

13 (76.5%)

10 (47.6%)

4 (50.0%)

(b) No

30 (13.5%)

13 (9.9%)

9 (19.6%)

1 (5.9%)

6 (28.6%)

1 (12.5%)

(c) Not Applicable

56 (25.1%)

35 (26.7%)

10 (21.7%)

3 (17.6%)

5 (23.8%)

3 (37.5%)

Question
10 continues the data tables question by
asking agency components whether each cell in a data table was provided
identification of row and column headers (when such table headers existed). Many agency components (38.6%) reported that
their web-based applications did not include data tables. For those web-based applications with data
tables, a majority of agency components reported success associating data cells
and header cells. Small and very small agency
components had more difficulty meeting this requirement.

The agency components’ responses are
summarized in the table below:

Data and Header Cell Association by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

104 (46.6%)

63 (48.1%)

21 (45.7%)

8 (47.1%)

10 (47.6%)

2 (25.0%)

(b) No

33 (14.8%)

14 (10.7%)

11 (23.9%)

1 (5.9%)

5 (23.8%)

2 (25.0%)

(c) Not Applicable

86 (38.6%)

54 (41.2%)

14 (30.4%)

8 (47.1%)

6 (28.6%)

4 (50.0%)

Question
11 asked agency components whether descriptive
titles were used for web-based applications with frames. A majority of agency components (61.9%)
reported that their web-based applications did not use frames. For those web-based applications with frames,
a majority of agency components reported success in meeting this requirement.

The following table provides the agency components’
responses:

Frame Accessibility by Number (Percent)
of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

70 (31.4%)

45 (34.4%)

13 (28.3%)

7 (41.2%)

4 (19.0%)

1 (12.5%)

(b) No

15 (6.7%)

6 (4.6%)

4 (8.7%)

1 (5.9%)

3 (14.3%)

1 (12.5%)

(c) Not Applicable

138 (61.9%)

80 (61.1%)

29 (63.0%)

9 (52.9%)

14 (66.7%)

6 (75.0%)

Question
12 asked agency components whether their
web-based applications were designed to avoid causing the screen to flicker
with a frequency greater than 2 Hz and lower than 55 Hz. Overall, most agency components reported that
their web-based applications did not flicker.

The agency components reported the following:

Designed to Avoid Screen Flicker by
Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

140 (62.8%)

82 (62.6%)

31 (67.4%)

10 (58.8%)

11 (52.4%)

6 (75.0%)

(b) No

9 (4.0%)

4 (3.1%)

0 (0.0%)

2 (11.8%)

3 (14.3%)

0 (0.0%)

(c) Not Applicable

74 (33.2%)

45 (34.4%)

15 (32.6%)

5 (29.4%)

7 (33.3%)

2 (25.0%)

Question
13 asked whether agency components provided a
text-only alternative because their surveyed web-based applications contained barriers
to people with disabilities, and whether the text-only alternative contained
the same information and was updated as often as the inaccessible surveyed
web-based application. A majority of
agency components (59.2%) reported that text-only alternatives were not needed
because their web-based applications did not contain barriers for people with
disabilities. When text-only alternatives
were provided, a majority of agency components reported success in providing up
to date, equivalent information and functionality.

The following table summarizes the responses
provided by the agency components:

Alternative Text-Only Page Availability
and Accessibility by Number (Percent) of Components in Differently-Sized
Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

60 (26.9%)

35 (26.7%)

15 (32.6%)

3 (17.6%)

5 (23.8%)

2 (25.0%)

(b) No

31 (13.9%)

17 (13.0%)

6 (13.0%)

3 (17.6%)

5 (23.8%)

0 (0.0%)

(c) Not Applicable

132 (59.2%)

79 (60.3%)

25 (54.3%)

11 (64.7%)

11 (52.4%)

6 (75.0%)

Question
14 asked agency components whether equivalent
text was made available for web-based applications using JavaScript or
Macromedia Flash scripts that affected content displayed to the user. Overall, a majority of agency components reported
that their web-based applications were accessible. Small and very small agency components had more
difficulty meeting this requirement when scripting was used.

The following table provides the specific
responses by the agency components:

Java/Flash Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

129 (57.8%)

78 (59.5%)

25 (54.3%)

13 (76.5%)

8 (38.1%)

5 (62.5%)

(b) No

38 (17.0%)

18 (13.7%)

10 (21.7%)

1 (5.9%)

7 (33.3%)

2 (25.0%)

(c) Not Applicable

56 (25.1%)

35 (26.7%)

11 (23.9%)

3 (17.6%)

6 (28.6%)

1 (12.5%)

Question
15 asked agency components whether they included a link to the plug-in
or other programmatic item required for accessing the content of their
web-based applications, and if that plug-in or other programmatic item itself
was accessible to people with disabilities.
A majority of agency components (59.2%) reported that their web-based
applications did not require a plug-in or other programmatic item. For those web-based applications that require
a plug-in or other programmatic item, a majority of agency components reported
success in meeting this requirement.

Specifically, the agency components provided
the following responses:

Plug-In or Other Programmatic Object Accessibility
by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

66 (29.6%)

37 (28.2%)

17 (37.0%)

5 (29.4%)

3 (14.3%)

4 (50.0%)

(b) No

25 (11.2%)

19 (14.5%)

2 (4.3%)

1 (5.9%)

3 (14.3%)

0 (0.0%)

(c) Not Applicable

132 (59.2%)

75 (57.3%)

27 (58.7%)

11 (64.7%)

15 (71.4%)

4 (50.0%)

Question
16 asked agency components about their use of online electronic
forms. Specifically, agency components
were asked whether each form permitted users of assistive technology to access
the information, field elements, and functionality required for completion and
submission of the form, including all directions and cues. Overall, a majority of agency components reported
success in meeting this requirement.

The agency components’ responses are
summarized in the table below:

Electronic Form Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

154 (69.1%)

98 (74.8%)

26 (56.5%)

14 (82.4%)

11 (52.4%)

5 (62.5%)

(b) No

38 (17.0%)

16 (12.2%)

11 (23.9%)

1 (5.9%)

8 (38.1%)

2 (25.0%)

(c) Not Applicable

31 (13.9%)

17 (13.0%)

9 (19.6%)

2 (11.8%)

2 (9.5%)

1 (12.5%)

Question
17 asked agency components whether web-based applications included
special links that allowed screen readers to skip over navigational links. Overall, a majority of agency components reported
including skip navigational links. Small
agency components had more difficulty meeting this requirement.

The following table provides the agency components’
responses:

Navigational Link Skipping by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

127 (57.0%)

76 (58.0%)

28 (60.9%)

12 (70.6%)

9 (42.9%)

2 (25.0%)

(b) No

40 (17.9%)

21 (16.0%)

6 (13.0%)

1 (5.9%)

10 (47.6%)

2 (25.0%)

(c) Not Applicable

56 (25.1%)

34 (26.0%)

12 (26.1%)

4 (23.5%)

2 (9.5%)

4 (50.0%)

Question
18 focused on web-based applications that imposed time limits on users. Specifically, agency components were
asked if users were alerted that they would be timed out and then given
sufficient time to indicate that more time was needed before actually being
timed out. Most agency components (62.8%)
reported that time limits were not used.
For those web-based applications that imposed time limits, a majority of
agency components reported success in meeting this requirement. Mid-size agency components were the most successful
in meeting this requirement.

The agency
components reported the following:

Time Limits by Number (Percent) of
Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

62 (27.8%)

36 (27.5%)

12 (26.1%)

8 (47.1%)

5 (23.8%)

1 (12.5%)

(b) No

21 (9.4%)

16 (12.2%)

2 (4.3%)

1 (5.9%)

2 (9.5%)

0 (0.0%)

(c) Not Applicable

140 (62.8%)

79 (60.3%)

32 (69.6%)

8 (47.1%)

14 (66.7%)

7 (87.5%)

Question
19 asked agency components whether their web-based applications
provided keyboard accessibility.
Keyboard accessibility allows people with disabilities to access a
program’s controls and features from a keyboard instead of a mouse or other
pointing device. Overall, a majority of
agency components reported success in meeting this requirement.

The following
table summarizes the responses provided by the agency components:

Keyboard Accessibility by Number
(Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

153 (68.6%)

92 (70.2%)

31 (67.4%)

14 (82.4%)

11 (52.4%)

5 (62.5%)

(b) No

22 (9.9%)

13 (9.9%)

3 (6.5%)

0 (0.0%)

5 (23.8%)

1 (12.5%)

(c) Not Applicable

48 (21.5%)

26 (19.8%)

12 (26.1%)

3 (17.6%)

5 (23.8%)

2 (25.0%)

Question
20 asked agency components whether their web-based applications
provided a well-defined on-screen indication of the current focus that moves
with keyboard navigation. The position
on a screen where an action will take place is referred to as the focus. Overall, a majority of agency components reported
success in ensuring that focus was programmatically exposed so that assistive
technology can track focus.

The following
table provides the specific responses by the agency components:

Screen Focus by Number (Percent) of
Components in Differently-Sized Agencies

Availability of User Interface
Information by Number (Percent) of Components in Differently-Sized Agencies

Answer

All

Very Large

Large

Mid-Size

Small

Very Small

(a) Yes

141 (63.2%)

82 (62.6%)

32 (69.6%)

13 (76.5%)

8 (38.1%)

6 (75.0%)

(b) No

32 (14.3%)

21 (16.0%)

4 (8.7%)

1 (5.9%)

5 (23.8%)

1 (12.5%)

(c) Not
applicable

50 (22.4%)

28 (21.4%)

10 (21.7%)

3 (17.6%)

8 (38.1%)

1 (12.5%)

Question
22 asked whether agency components used text captioning for
multimedia content. Such accessibility
features are used to make multimedia features accessible to users with hearing
and/or visual impairments. Overall, most
agency components (74.0%) reported that their web-based applications did not
include multimedia content. The agency components’ responses are summarized in
the table below:

Captioning by Number (Percent) of
Components in Differently-Sized Agencies

(A) DEVELOPMENT, PROCUREMENT,
MAINTENANCE, OR USE OF ELECTRONIC AND INFORMATION TECHNOLOGY. --When developing,
procuring, maintaining, or using electronic and information technology, each
Federal department or agency, including the United States Postal Service, shall
ensure, unless an undue burden would be imposed on the department or agency,
that the electronic and information technology allows, regardless of the type
of medium of the technology--

(i)
individuals with disabilities who are Federal employees to have access to and
use of information and data that is comparable to the access to and use of the
information and data by Federal employees who are not individuals with
disabilities; and

(ii) individuals with
disabilities who are members of the public seeking information or services from
a Federal department or agency to have access to and use of information and
data that is comparable to the access to and use of the information and data by
such members of the public who are not individuals with disabilities.

(B) ALTERNATIVE MEANS
EFFORTS. --When development, procurement,
maintenance, or use of electronic and information technology that meets the
standards published by the Access Board under paragraph (2) would impose an
undue burden, the Federal department or agency shall provide individuals with
disabilities covered by paragraph (1) with the information and data involved by
an alternative means of access that allows the individual to use the information
and data.

(2) ELECTRONIC AND INFORMATION
TECHNOLOGY STANDARDS. --

(A) IN GENERAL.–Not later than
18 months after August 7, 1998, the Architectural and Transportation Barriers
Compliance Board (referred to in this section as the 'Access Board'), after
consultation with the Secretary of Education, the Administrator of General
Services, the Secretary of Commerce, the Chairman of the Federal Communications
Commission, the Secretary of Defense, and the head of any other Federal
department or agency that the Access Board determines to be appropriate,
including consultation on relevant research findings, and after consultation
with the electronic and information technology industry and appropriate public
or nonprofit agencies or organizations, including organizations representing
individuals with disabilities, shall issue and publish standards setting
forth--

(i)
for purposes of this section, a definition of electronic and information
technology that is consistent with the definition of information technology
specified in section 5002(3) of the Clinger-Cohen Act of 1996 (40 U.S.C. 1401(3)); and

(ii) the
technical and functional performance criteria necessary to implement the
requirements set forth in paragraph (1).

(3) INCORPORATION OF
STANDARDS. --Not later than 6 months after the Access Board publishes the
standards required under paragraph (2), the Federal Acquisition Regulatory
Council shall revise the Federal Acquisition Regulation and each Federal
department or agency shall revise the Federal procurement policies and directives
under the control of the department or agency to incorporate those standards. Not later than 6 months after the Access Board revises any standards required
under paragraph (2), the Council shall revise the Federal Acquisition
Regulation and each appropriate Federal department or agency shall revise the
procurement policies and directives, as necessary, to incorporate the
revisions.

(4) ACQUISITION PLANNING. --In
the event that a Federal department or agency determines that compliance with
the standards issued by the Access Board under paragraph (2) relating to
procurement imposes an undue burden, the documentation by the department or
agency supporting the procurement shall explain why compliance creates an undue
burden.

(5) EXEMPTION FOR NATIONAL
SECURITY SYSTEMS. --This section shall not apply to national security systems,
as that term is defined in section 5142 of the Clinger-Cohen Act of 1996 (40
U.S.C. 1452).

(6) CONSTRUCTION. --

(A) EQUIPMENT. --In a case in
which the Federal Government provides access to the public to information or
data through electronic and information technology, nothing in this section
shall be construed to require a Federal department or agency--

(i)
to make equipment owned by the Federal Government available for access and use
by individuals with disabilities covered by paragraph (1) at a location other
than that where the electronic and information technology is provided to the
public; or

(ii) to
purchase equipment for access and use by individuals with disabilities covered
by paragraph (1) at a location other than that where the electronic and
information technology is provided to the public.

(B) SOFTWARE AND PERIPHERAL
DEVICES. --Except as required to comply with standards issued by the Access
Board under paragraph (2), nothing in paragraph (1) requires the installation
of specific accessibility-related software or the attachment of a specific
accessibility-related peripheral device at a workstation of a Federal employee
who is not an individual with a disability.

(b) TECHNICAL ASSISTANCE. --The
Administrator of General Services and the Access Board shall provide technical
assistance to individuals and Federal departments and agencies concerning the
requirements of this section.

(c) AGENCY EVALUATIONS. --Not
later than 6 months after August 7, 1998, the head of each Federal department
or agency shall evaluate the extent to which the electronic and information
technology of the department or agency is accessible to and usable by
individuals with disabilities described in subsection (a)(1), compared to the
access to and use of the technology by individuals described in such subsection
who are not individuals with disabilities, and submit a report containing the
evaluation to the Attorney General.

(d) REPORTS. --

(1) INTERIM REPORT. --Not later
than 18 months after August 7, 1998, the Attorney General shall prepare and
submit to the President a report containing information on and recommendations
regarding the extent to which the electronic and information technology of the
Federal Government is accessible to and usable by individuals with disabilities
described in subsection (a)(1).

(2) BIENNIAL REPORTS. --Not
later than 3 years after August 7, 1998, and every 2 years thereafter, the
Attorney General shall prepare and submit to the President and Congress a
report containing information on and recommendations regarding the state of
Federal department and agency compliance with the requirements of this section,
including actions regarding individual complaints under subsection (f).

(e) COOPERATION. --Each head of
a Federal department or agency (including the Access Board, the Equal
Employment Opportunity Commission, and the General Services Administration)
shall provide to the Attorney General such information as the Attorney General
determines is necessary to conduct the evaluations under subsection (c) and
prepare the reports under subsection (d).

(f) ENFORCEMENT. --

(1) GENERAL. --

(A) COMPLAINTS.–Effective 6
months after the date of publication by the Access Board of final standards described
in subsection (a)(2), any individual with a disability may file a complaint
alleging that a Federal department or agency fails to comply with subsection
(a)(1) in providing electronic and information technology.

(B) APPLICATION. -This
subsection shall apply only to electronic and information technology that is
procured by a Federal department or agency not less than 6 months after the
date of publication by the Access Board of final standards described in
subsection (a)(2).

(2) ADMINISTRATIVE COMPLAINTS. -Complaints
filed under paragraph (1) shall be filed with the Federal department or agency
alleged to be in noncompliance. The Federal department or agency receiving the
complaint shall apply the complaint procedures established to implement section
794 of this title for resolving allegations of discrimination in a federally
conducted program or activity.

(3) CIVIL ACTIONS. --The
remedies, procedures, and rights set forth in sections 794a(a)(2) and 794a(b)
of this title shall be the remedies, procedures, and rights available to any
individual with a disability filing a complaint under paragraph (1).

(g) APPLICATION TO OTHER
FEDERAL LAWS. -This section shall not be construed to limit any right, remedy,
or procedure otherwise available under any provision of Federal law (including
sections 791 through 794(a) of this title) that provides greater or equal
protection for the rights of individuals with disabilities than this section.

The purpose of this part is to
implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). Section 508 requires that when Federal agencies develop, procure,
maintain, or use electronic and information technology, Federal employees with
disabilities have access to and use of information and data that is comparable
to the access and use by Federal employees who are not individuals with
disabilities, unless an undue burden would be imposed on the agency. Section
508 also requires that individuals with disabilities, who are members of the
public seeking information or services from a Federal agency, have access to
and use of information and data that is comparable to that provided to the
public who are not individuals with disabilities, unless an undue burden would
be imposed on the agency.

§ 1194.2
Application.

(a) Products covered by this
part shall comply with all applicable provisions of this part. When developing,
procuring, maintaining, or using electronic and information technology, each
agency shall ensure that the products comply with the applicable provisions of
this part, unless an undue burden would be imposed on the agency.

(1) When compliance with the
provisions of this part imposes an undue burden, agencies shall provide
individuals with disabilities with the information and data involved by an
alternative means of access that allows the individual to use the information
and data.

(2) When procuring a product,
if an agency determines that compliance with any provision of this part imposes
an undue burden, the documentation by the agency supporting the procurement
shall explain why, and to what extent, compliance with each such provision
creates an undue burden.

(b) When procuring a product,
each agency shall procure products which comply with the provisions in this
part when such products are available in the commercial marketplace or when
such products are developed in response to a Government solicitation. Agencies
cannot claim a product as a whole is not commercially available because no
product in the marketplace meets all the standards. If products are
commercially available that meet some but not all of
the standards, the agency must procure the product that best meets the
standards.

(c) Except as provided by §
1194.3(b), this part applies to electronic and information technology
developed, procured, maintained, or used by agencies directly or used by a
contractor under a contract with an agency which requires the use of such
product, or requires the use, to a significant extent, of such product in the
performance of a service or the furnishing of a product.

§ 1194.3 General exceptions.

(a) This part does not apply to
any electronic and information technology operated by agencies, the function,
operation, or use of which involves intelligence activities, cryptologic activities related to national security,
command and control of military forces, equipment that is an integral part of a
weapon or weapons system, or systems which are critical to the direct
fulfillment of military or intelligence missions. Systems which are critical to
the direct fulfillment of military or intelligence missions do not include a
system that is to be used for routine administrative and business applications
(including payroll, finance, logistics, and personnel management applications).

(b) This part does not apply to
electronic and information technology that is acquired by a contractor
incidental to a contract.

(c) Except as required to
comply with the provisions in this part, this part does not require the
installation of specific accessibility-related software or the attachment of an
assistive technology device at a workstation of a Federal employee who is not
an individual with a disability.

(d) When agencies provide
access to the public to information or data through electronic and information
technology, agencies are not required to make products owned by the agency
available for access and use by individuals with disabilities at a location
other than that where the electronic and information technology is provided to
the public, or to purchase products for access and use by individuals with
disabilities at a location other than that where the electronic and information
technology is provided to the public.

(e) This part shall not be
construed to require a fundamental alteration in the nature of a product or its
components.

(f) Products located in spaces
frequented only by service personnel for maintenance, repair, or occasional
monitoring of equipment are not required to comply
with this part.

§ 1194.4 Definitions.

The following definitions apply
to this part:

Agency. Any Federal department or agency, including the United States
Postal Service.

Alternate
formats. Alternate formats usable by people with disabilities may
include, but are not limited to, Braille, ASCII text, large print, recorded
audio, and electronic formats that comply with this part.

Alternate
methods. Different means of providing information, including product
documentation, to people with disabilities. Alternate methods may include, but
are not limited to, voice, fax, relay service, TTY, Internet posting,
captioning, text-to-speech synthesis, and audio description.

Assistive
technology. Any item, piece of equipment, or system, whether
acquired commercially, modified, or customized, that is commonly used to
increase, maintain, or improve functional capabilities of individuals with
disabilities.

Electronic
and information technology. Includes information technology and any
equipment or interconnected system or subsystem of equipment,
that is used in the creation, conversion, or duplication of data or
information. The term electronic and information technology includes, but is
not limited to, telecommunications products (such as telephones), information
kiosks and transaction machines, World Wide Web sites, multimedia, and office
equipment such as copiers and fax machines. The term does not include any
equipment that contains embedded information technology that is used as an
integral part of the product, but the principal function of which is not the
acquisition, storage, manipulation, management, movement, control, display,
switching, interchange, transmission, or reception of data or information. For
example, HVAC (heating, ventilation, and air conditioning) equipment such as
thermostats or temperature control devices, and medical equipment where
information technology is integral to its operation, are
not information technology.

Information
technology. Any equipment or interconnected system or subsystem of
equipment, that is used in the automatic acquisition, storage, manipulation,
management, movement, control, display, switching, interchange, transmission,
or reception of data or information. The term information technology includes
computers, ancillary equipment, software, firmware and similar procedures,
services (including support services), and related resources.

Self
Contained, Closed Products. Products that generally have embedded
software and are commonly designed in such a fashion that a user cannot easily
attach or install assistive technology. These products include, but are not
limited to, information kiosks and information transaction machines, copiers,
printers, calculators, fax machines, and other similar types of products.

Telecommunications. The transmission, between or among points specified by the
user, of information of the user's choosing, without change in the form or
content of the information as sent and received.

TTY. An abbreviation for teletypewriter. Machinery or
equipment that employs interactive text based communications through the
transmission of coded signals across the telephone network. TTYs may include,
for example, devices known as TDDs (telecommunication display devices or
telecommunication devices for deaf persons) or computers with special modems. TTYs are also called text telephones.

Undue
burden. Undue burden means significant difficulty or expense. In
determining whether an action would result in an undue burden, an agency shall
consider all agency resources available to the program or component for which
the product is being developed, procured, maintained, or used.

§ 1194.5
Equivalent facilitation.

Nothing in this part is
intended to prevent the use of designs or technologies as alternatives to those
prescribed in this part provided they result in substantially equivalent or
greater access to and use of a product for people with disabilities.

Subpart B -- Technical
Standards

§ 1194.21 Software
applications and operating systems.

(a) When software is designed
to run on a system that has a keyboard, product functions shall be executable
from a keyboard where the function itself or the result of performing a
function can be discerned textually.

(b) Applications shall not
disrupt or disable activated features of other products that are identified as
accessibility features, where those features are developed and documented
according to industry standards. Applications also shall not disrupt or disable
activated features of any operating system that are identified as accessibility
features where the application programming interface for those accessibility
features has been documented by the manufacturer of the operating system and is
available to the product developer.

(c) A well-defined on-screen
indication of the current focus shall be provided that moves among interactive
interface elements as the input focus changes. The focus shall be
programmatically exposed so that assistive technology can track focus and focus
changes.

(d) Sufficient information
about a user interface element including the identity, operation and state of
the element shall be available to assistive technology. When an image
represents a program element, the information conveyed by the image must also
be available in text.

(e) When bitmap images are used
to identify controls, status indicators, or other programmatic elements, the
meaning assigned to those images shall be consistent throughout an application's
performance.

(f) Textual information shall
be provided through operating system functions for displaying text. The minimum
information that shall be made available is text content, text input caret
location, and text attributes.

(h) When animation is
displayed, the information shall be displayable in at least one non-animated
presentation mode at the option of the user.

(i)
Color coding shall not be used as the only means of conveying information,
indicating an action, prompting a response, or distinguishing a visual element.

(j) When a product permits a
user to adjust color and contrast settings, a variety of color selections
capable of producing a range of contrast levels shall be provided.

(k) Software shall not use
flashing or blinking text, objects, or other elements having a flash or blink
frequency greater than 2 Hz and lower than 55 Hz.

(l) When electronic forms are
used, the form shall allow people using assistive technology to access the
information, field elements, and functionality required for completion and
submission of the form, including all directions and cues.

(a) A text equivalent for every
non-text element shall be provided (e.g. , via "alt", "longdesc", or in element content).

(b) Equivalent alternatives for
any multimedia presentation shall be synchronized with the presentation.

(c) Web pages shall be designed
so that all information conveyed with color is also available without color,
for example from context or markup.

(d) Documents shall be
organized so they are readable without requiring an associated style sheet.

(e) Redundant text links shall be
provided for each active region of a server-side image map.

(f) Client-side image maps
shall be provided instead of server-side image maps except where the regions
cannot be defined with an available geometric shape.

(g) Row and column headers
shall be identified for data tables.

(h) Markup shall be used to
associate data cells and header cells for data tables that have two or more
logical levels of row or column headers.

(i)
Frames shall be titled with text that facilitates frame identification and navigation.

(j) Pages shall be designed to
avoid causing the screen to flicker with a frequency greater than 2 Hz and
lower than 55 Hz.

(k) A text-only page, with
equivalent information or functionality, shall be provided to make a web site
comply with the provisions of this part, when compliance cannot be accomplished
in any other way. The content of the text-only page shall be updated whenever
the primary page changes.

(l) When pages utilize
scripting languages to display content, or to create interface elements, the
information provided by the script shall be identified with functional text
that can be read by assistive technology.

(m) When a web page requires
that an applet, plug-in or other application be
present on the client system to interpret page content, the page must provide a
link to a plug-in or applet that complies with § 1194.21(a) through (l).

(n) When electronic forms are
designed to be completed on-line, the form shall allow people using assistive
technology to access the information, field elements, and functionality
required for completion and submission of the form, including all directions
and cues.

(p) When a timed response is
required, the user shall be alerted and given sufficient time to indicate more
time is required.

Note to § 1194.22: 1. The Board interprets paragraphs (a) through (k) of this section as consistent
with the following priority 1 Checkpoints of the Web Content Accessibility
Guidelines 1.0 (WCAG 1.0) (May 5, 1999) published by the Web Accessibility
Initiative of the World Wide Web Consortium:

Section 1194.22 Paragraph

WCAG 1.0 Checkpoint

(a)

1.1

(b)

1.4

(c)

2.1

(d)

6.1

(e)

1.2

(f)

9.1

(g)

5.1

(h)

5.2

(i)

12.1

(j)

7.1

(k)

11.4

2. Paragraphs (l), (m), (n), (o), and (p) of this section are different from
WCAG 1.0. Web pages that conform to WCAG 1.0, level A (i.e. , all priority 1
checkpoints) must also meet paragraphs (l), (m), (n), (o), and (p) of this
section to comply with this section. WCAG 1.0 is available at http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505.

§ 1194.23 Telecommunications
products.

(a) Telecommunications products
or systems which provide a function allowing voice communication and which do
not themselves provide a TTY functionality shall provide a standard
non-acoustic connection point for TTYs. Microphones shall be capable of being
turned on and off to allow the user to intermix speech with TTY use.

(d) Voice mail, messaging,
auto-attendant, and interactive voice response telecommunications systems that
require a response from a user within a time interval, shall give an alert when
the time interval is about to run out, and shall provide sufficient time for
the user to indicate more time is required.

(e) Where provided, caller
identification and similar telecommunications functions shall also be available
for users of TTYs, and for users who cannot see displays.

(f) For transmitted voice
signals, telecommunications products shall provide a gain adjustable up to a
minimum of 20 dB. For incremental volume control, at least one intermediate
step of 12 dB of gain shall be provided.

(g) If the telecommunications
product allows a user to adjust the receive volume, a function shall be
provided to automatically reset the volume to the default level after every
use.

(h) Where a telecommunications
product delivers output by an audio transducer which is normally held up to the
ear, a means for effective magnetic wireless coupling to hearing technologies
shall be provided.

(j) Products that transmit or
conduct information or communication, shall pass through cross-manufacturer,
non-proprietary, industry-standard codes, translation protocols, formats or
other information necessary to provide the information or communication in a
usable format. Technologies which use encoding, signal compression, format
transformation, or similar techniques shall not remove information needed for
access or shall restore it upon delivery.

(k) Products which have
mechanically operated controls or keys, shall comply with the following:

(1) Controls and keys shall be
tactilely discernible without activating the controls or keys.

(2) Controls and keys shall be
operable with one hand and shall not require tight grasping, pinching, or
twisting of the wrist. The force required to activate controls and keys shall
be 5 lbs. (22.2 N) maximum.

(3) If key repeat is supported,
the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate
shall be adjustable to 2 seconds per character.

(4) The status of all locking
or toggle controls or keys shall be visually discernible, and discernible
either through touch or sound.

§ 1194.24 Video and
multimedia products.

(a) All analog television displays
13 inches and larger, and computer equipment that includes analog television
receiver or display circuitry, shall be equipped with caption decoder circuitry
which appropriately receives, decodes, and displays closed captions from
broadcast, cable, videotape, and DVD signals. As soon as practicable, but not
later than July 1, 2002, widescreen digital television (DTV) displays measuring
at least 7.8 inches vertically, DTV sets with conventional displays measuring
at least 13 inches vertically, and stand-alone DTV tuners, whether or not they
are marketed with display screens, and computer equipment that includes DTV
receiver or display circuitry, shall be equipped with caption decoder circuitry
which appropriately receives, decodes, and displays closed captions from
broadcast, cable, videotape, and DVD signals.

(b) Television tuners,
including tuner cards for use in computers, shall be equipped with secondary
audio program playback circuitry.

(c) All training and
informational video and multimedia productions which support the agency's
mission, regardless of format, that contain speech or other audio information
necessary for the comprehension of the content, shall be open or closed
captioned.

(d) All training and
informational video and multimedia productions which support the agency's
mission, regardless of format, that contain visual information necessary for
the comprehension of the content, shall be audio described.

(a) Self contained products
shall be usable by people with disabilities without requiring an end-user to
attach assistive technology to the product. Personal headsets for private
listening are not assistive technology.

(b) When a timed response is
required, the user shall be alerted and given sufficient time to indicate more
time is required.

(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method
shall be provided that complies with § 1194.23 (k) (1) through (4).

(d) When biometric forms of
user identification or control are used, an alternative form of identification
or activation, which does not require the user to possess particular biological
characteristics, shall also be provided.

(e) When products provide
auditory output, the audio signal shall be provided at a standard signal level
through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio
at anytime.

(f) When products deliver voice
output in a public area, incremental volume control shall be provided with
output amplification up to a level of at least 65 dB. Where the ambient noise
level of the environment is above 45 dB, a volume gain of at least 20 dB above
the ambient level shall be user selectable. A function shall be provided to
automatically reset the volume to the default level after every use.

(g) Color coding shall not be
used as the only means of conveying information, indicating an action,
prompting a response, or distinguishing a visual element.

(h) When a product permits a
user to adjust color and contrast settings, a range of color selections capable
of producing a variety of contrast levels shall be provided.

(i)
Products shall be designed to avoid causing the screen to flicker with a
frequency greater than 2 Hz and lower than 55 Hz.

(j) Products which are
freestanding, non-portable, and intended to be used in one location and which
have operable controls shall comply with the following:

(1) The position of any
operable control shall be determined with respect to a vertical plane, which is
48 inches in length, centered on the operable control, and at the maximum
protrusion of the product within the 48 inch length (see Figure 1 of
this part).

(2) Where any operable control
is 10 inches or less behind the reference plane, the height shall be 54 inches
maximum and 15 inches minimum above the floor.

(3) Where any operable control
is more than 10 inches and not more than 24 inches behind the reference plane,
the height shall be 46 inches maximum and 15 inches minimum above the floor.

(4) Operable controls shall not
be more than 24 inches behind the reference plane (see Figure 2 of this part).

(b) If a product utilizes touchscreens or touch-operated controls, an input method
shall be provided that complies with § 1194.23 (k) (1) through (4).

(c) When biometric forms of
user identification or control are used, an alternative form of identification
or activation, which does not require the user to possess particular biological
characteristics, shall also be provided.

(d) Where provided, at least
one of each type of expansion slots, ports and connectors shall comply with
publicly available industry standards.

Subpart C -- Functional
Performance Criteria

§ 1194.31 Functional
performance criteria.

(a) At least one mode of
operation and information retrieval that does not require user vision shall be
provided, or support for assistive technology used by people who are blind or visually
impaired shall be provided.

(b) At least one mode of
operation and information retrieval that does not require visual acuity greater
than 20/70 shall be provided in audio and enlarged print output working
together or independently, or support for assistive technology used by people
who are visually impaired shall be provided.

(c) At least one mode of
operation and information retrieval that does not require user hearing shall be
provided, or support for assistive technology used by people who are deaf or
hard of hearing shall be provided.

(d) Where audio information is
important for the use of a product, at least one mode of operation and
information retrieval shall be provided in an enhanced auditory fashion, or
support for assistive hearing devices shall be provided.

(e) At least one mode of
operation and information retrieval that does not require user speech shall be
provided, or support for assistive technology used by people with disabilities
shall be provided.

(f) At least one mode of
operation and information retrieval that does not require fine motor control or
simultaneous actions and that is operable with limited reach and strength shall
be provided.

Subpart D -- Information,
Documentation, and Support

§ 1194.41 Information,
documentation, and support.

(a) Product support
documentation provided to end-users shall be made available in alternate
formats upon request, at no additional charge.

(b) End-users shall have access
to a description of the accessibility and compatibility features of products in
alternate formats or alternate methods upon request, at no additional charge.

(c) Support services for
products shall accommodate the communication needs of end-users with
disabilities.

[3] The survey and the report would not have been possible without substantial assistance
from the General Services Administration and other agencies.

[4] The federal executive Cabinet level agencies, independent agencies, and boards, commissions and committees were identified from the United States government’s official web portal, USA.gov.

[5]The calculation of average number of
FTEs and dollars were based on responses from 110 agency components that
reported establishing a Section 508 office or program. A total of 318 agency components participated
in the survey. Thus, the average number
of FTEs and dollars represent only 35% of the total number of agency components
that participated in the survey.

[6]The Department of Health and Human Services has taken such an approach in its Guidance for Exchange and Medicaid Information Technology (IT) Systems, Version 2.0 (May 2011): “Systems should include usability features or functions that accommodate the needs of persons with disabilities, including those who use assistive technology. State enrollment and eligibility systems are subject to the program accessibility provisions of Section 504 of the Rehabilitation Act, which include an obligation to provide individuals with disabilities an equal and effective opportunity to benefit from or participate in a program, including those offered through electronic and information technology. At this time, HHS will consider a recipient’s websites, interactive kiosks, and other information systems addressed by Section 508 standards as being in compliance with Section 504 if such technologies meet those standards. We encourage states to follow either the Section 508 guidelines or guidelines that provider greater accessibility to individuals with disabilities. States may wish to consult the latest Section 508 guidelines issued by the US Access Board ….”

[8] The calculation of average number of
FTEs and dollars were based on responses from 110 agency components that
reported establishing a Section 508 office or program. A total of 318 agency components participated
in the survey. Thus, the average number
of FTEs and dollars represent only 35% of the total number of agency components
that participated in the survey.

[9] The calculation of average number of
dollars was based on responses from 42 agency components that tracked their
spending to implement and comply with Section 508. A total of 318 agency components participated
in the survey. Thus, the average number
of dollars represents only 13% of the total number of agency components that
participated in the survey.

[10] The calculation of average number of
FTEs and dollars were based on responses from 110 agency components that
reported establishing a Section 508 office or program. A total of 318 agency components participated
in the survey. Thus, the average number
of FTEs and dollars represent only 35% of the total number of agency components
that participated in the survey.

[11] The calculation of average number of
FTEs was based on responses from 110 agency components that reported
establishing a Section 508 office or program.
A total of 318 agency components participated in the survey. Thus, the average number of FTEs represents
only 35% of the total number of agency components that participated in the
survey.

[12] The calculation of average number of
dollars was based on responses from 110 agency components that reported establishing
a Section 508 office or program. A total
of 318 agency components participated in the survey. Thus, the average number of dollars
represents only 35% of the total number of agency components that participated
in the survey.

[13] The calculation of average number of
dollars was based on responses from 42 agency components that tracked their
spending to implement and comply with Section 508. A total of 318 agency components participated
in the survey. Thus, the average number
of dollars represents only 13% of the total number of agency components that
participated in the survey.

[14] The calculation of average number of
dollars was based on responses from 42 agency components that tracked their
spending to implement and comply with Section 508. A total of 318 agency components participated
in the survey. Thus, the average number
of dollars represents only 13% of the total number of agency components that
participated in the survey.

[15] Alternate formats usable by people with disabilities include, but are not
limited to, Braille, ASCII text, large print, recorded audio,
and electronic formats. Alternate
methods are different means of providing information, including product
documentation, to people with disabilities. Alternate methods include, but are not limited
to, voice, fax, relay service, TTY, Internet posting, captioning,
text-to-speech synthesis, and audio description.

[16] Section 508(a) requires federal
departments and agencies, including the United States Postal Service, to ensure
the accessibility of their EIT when they develop, procure, maintain, or use
that EIT. Section 508(f) authorizes
civil actions and administrative complaints by persons with disabilities for
violations of Section 508(a). This
section, however, is limited to electronic and information technology procured
after June 21, 2001.

[17] Voluntary Product Accessibility Template or VPAT is a non-governmental tool voluntarily used by vendors to document a product’s conformance with the accessibility standards under Section 508.

[18] Section 508 EIT Accessibility Standards are not applicable for “[p]roducts located in spaces frequented only by service
personnel for maintenance, repair, or occasional monitoring of equipment.” 36 C.F.R. § 1194.3(f).

[19] Section 508 EIT Accessibility Standards are not applicable for “[p]roducts located in spaces frequented only by service
personnel for maintenance, repair, or occasional monitoring of equipment.” 36 C.F.R. § 1194.3(f).

[20] Answer choices (a) and (b) have been combined to present the overall number (and percentage) of agency components that require approval at the top agency or top component level.

[21] Federal agencies have additional
longstanding obligations that are enforceable under sections 501 and 504 of the
Rehabilitation Act. Thus, if individuals
file complaints pertaining to EIT, agencies should review the allegations to
determine if they more properly allege violations of sections 501 or 504 of the
Rehabilitation Act.

[22] In addition to administrative
complaints, individuals with disabilities may file civil lawsuits in federal district
court for violations of Section 508. The
remedies available in court proceedings are defined by sections 505(a)(2) and
505(b) of the Rehabilitation Act, 29 U.S.C. §§ 794a(a)(2) and 794a(b), and
include injunctive relief and attorneys’ fees, but do not include monetary
damages. SeeLane v. Pena, 518
U.S. 187 (1996).

[23] The number of administrative complaints and civil actions are based on information since June 21, 2001, the
effective date of the Section 508 EIT Accessibility Standards.